papa see there yes yes can you hear me we can hear you we can't see but i guess you're just doing this by oh there you are now we can see you all right an abandonment of our federal courts most important duties under the us constitution but the message relations exception relied upon by the respondents and queer polow is an aberration here supreme court opinions written by the latest same justice ruth bader ginsburg lower courts were scolded for abusing such an abstention doctrines to dismiss invalid federal claims that include is at least as important as the prison inmates grievances and proctor rd the federal election law makes it clear that any person and i stress any person who participates in the misappropriation of campaign funds is guilty of a federal crime the bank respondents brief sets were the order was process for using the election commission's record of the leader's violation that process could not take its course until after the election and it is inconceivable that congress intended to permit the thieves in this case to influence the outcome of a federal election by disallow be timely access to federal court recourse transparency and accountability were also under the carpet to follow the respondents reasoning both the letter and spirit of federal election  could be circumvented by rd party operatives and the divorce case there by opening the door to future crimes of the psoriatics would set the precedent contrasting with such convictions  congressman duncan hunter and his wife in california were campaigning misappropriations with the upcoming argument by the new york attorney general this may be a good time for me to ask why my adversaries here are not being prosecuted for failure to return campaign funds that have long been applied to private purposes the seizure of funds is not in dispute attorney and recruitment was also scheduled to be present pretty with drew i think two days ago obviously he's awaiting accountability and his we can't get an explanation from him why he hasn't same identification number and the bank has chosen not to be here either at the very least the bank could have held the funds unless crow for future judge resolution as the insurance company did in papers that the imposition of the filing injunction was wholly unsupported by the record but i didn't interpret what happened to well to be the actual filing of what a geisha injunction the magistrate judge said you should get an order that you can order show cause as to why you should be barred from filing future lawsuits without permission of the court that the short adopted the are its entirety and its judgement said in the future plaintiff's attracted to show cause in writing as to why he should not be barred from finally complaints that wave of court and there is no date set for that but i didn't interpret those two things together to to actually be imposing the following junction because we're supposed to give you notice the courts but if you notice before such an injunction is issued so i guess my question to you argument why didn't you respond why didn't you put another is no date given but why don't you put in something as to why the should unifying injunction or would you intend to do that well as you say there's no what they again morning may it please the court caroline stilson on behalf of the state defendants the district court's decision should be affirmed for any one of several independent reasons i plan to start with abstention and immunity but i will of course be happy to answer any questions  on any of the other grounds for dismissal or the limited filing and at me just ask you a question if you start do you agree with the proposition that there is no filing injunction in place i think that the what happened happened below is a little bit irregular and that it is difficult to interpret as i interpreted it the what the magistrate judge did was recommend that a limited filing injunction be put in place and that it could be interpreted that he was that  papas was then given notice by that are in our he did file objections to that as to why a limited filing injunction should not be put in place that it that's at the appendix at thirty four dollars and the district court's order could be read as suggesting that in the future to file a complaint he would need to get permission of the court of course if the court has any concerns about that that he would have the opportunity to file something below strictly on the issue of whether or not a showing cause to contest a limited filing a junction if this court thinks that opportunity they would wait for the district court to actually do that and the date would be set right isn't that the moment course that is certainly than the normal course around or again he did in fact mr papas did in fact submit papers in this case explaining why he didn't think to leave a filing injunction was appropriate but of course this court is free to let to let this go back on the on the limited issue to allow him to show cause going forward on just on the question of the filing injunction and also that the final injunction would be limited to the subject matter of this case that right there and there are case law would be a general filing junction that you can follow me once you have to be related to the subject matter of this litigation i believe that is correct your honor yes turning to the question of warranted in this case under the domestic relations abstention doctrine because the grab a man mr papa says claims is a dispute with the outcome of the divil of the state divorce proceeding papa says primary request is for an order invalidating the decisions that he lost in the state this is equally true of mr papas this campaign related allegations his allegations complain about the entry of a money judgment and justice lawrence's refusal to lift a restraint or straight on his accounts as part of the match michael dispute let me interject a question domestic relations exception to subject matter jurisdiction applied only in diversity cases now i understand that but my math but my point is if it's been previously negated it doesn't cease to be barred by  change in governing law then even if the specified elements of collateral stoffel are present reexamination of the legal issue is appropriate when there has been a change in the legal landscape that was this court's decision and faulkner on national geographic and the supreme court has also in this case of course justice lawrence was not a party to the prior action and so there's a there's a there's an open question as to whether the questions of issue a stop all that apply and protect him of course the state would have no objection if that's the grounds on which this court wanted to rule is looking for essential a retrospective relief in the sense that what he is asking for is a declaration that previous orders of the district court of the gist of the state judicial divorce proceedings were were invalid and just one point on the also provides procedures to expedite the f e c is ability to take to bring litigation when there is probable cause for an election law violation in the media forty five days before an election and there's been no showing by mr papas that those procedures have in any way hindered the f e c is ability to timely correct any and the election law concerns but in any event because the f e c is these exclude has is the exclusive actor to enforce the election laws that among other reasons precludes them from bring any now that donations from rd parties that were intended for campaign purposes were stolen and that's against the law and that issue reserve the main thrust of