Leonard v. Hammond

ERVIN, Circuit Judge:

Plaintiffs/appellants Leonard and Casselbury brought this action after each had been imprisoned under separate civil contempt orders for failure to pay child support. Plaintiffs claim that their due process rights were violated when defendants, Neely and Hammond, state trial court judges presiding over the contempt hearings, failed to appoint counsel for plaintiffs, who were indigent at the time. The district court dismissed the action on Younger abstention grounds. Finding that plaintiffs’ claim, cognizable only in a habeas corpus application, has not been presented to…