Sanai v. Kruger

── Sanai v. Kruger ── Court: Court of Appeals for the Ninth Circuit Date: May 08, 2026 Category: General NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAY 8 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT CYRUS MARK SANAI, Solicitor, No. 25-2937 D.C. No. Plaintiff - Appellant, 3:23-cv-01057-AMO v. MEMORANDUM* Judge LEONDRA KRUGER; JOSHUA P. GROBAN; MARTIN J. JENKINS; KELLI EVANS; CAROL CORRIGAN; GOODWIN LIU; Honorable PATRICIA GUERRERO, Chief Justice, Defendants - Appellees. Appeal from the United States District Court for the Northern District of California Araceli Martinez-Olguin, District Judge, Presiding Submitted April 30, 2026** Before: N.R. SMITH, BUMATAY, and H.A. THOMAS, Circuit Judges. Cyrus Mark Sanai, a California attorney subject to California State Bar disciplinary proceedings, filed a pro se action under 42 U.S.C. § 1983 against the * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). Justices of the California Supreme Court, alleging that the Bar disciplinary process is constitutionally defective. We previously affirmed the district court’s dismissal of Sanai’s claims on the basis of abstention under Younger v. Harris, 401 U.S. 37 (1971), and its denial of Sanai’s post-judgment motions under Rules 59 and 60(b) of the Federal Rules of Civil Procedure. See Roshan v. Lawrence, No. 21-15771, 2024 WL 339100 (9th Cir. Jan. 30, 2024), cert. denied, 145 S. Ct. 1139 (2025), and cert. denied sub nom., Sanai v. Lawrence, 145 S. Ct. 1140 (2025). Sanai now appeals the district court’s denial of his motion for relief from judgment pursuant to Rule 60(b)(6).1 In his motion, Sanai argued that the Supreme Court’s recent opinion in Williams v. Reed, 604 U.S. 168 (2025), presented an intervening change in the law that warrants vacatur of the judgment. We have jurisdiction under 28 U.S.C. § 1291. We review a district court’s denial of a motion for relief from judgment under Rule 60(b) for abuse of discretion. Flores v. Rosen, 984 F.3d 720, 731 (9th Cir. 2020). We affirm. 1 We consider only Sanai’s initial opening brief (Dkt. No. 13). See 9th Cir. R. 32- 1(a). In doing so, we decline to revisit Sanai’s arguments in support of default judgment, equitable relief, and reassignment, which we previously rejected in connection with Sanai’s first appeal. See Roshan, 2024 WL 339100, at *2 (finding Sanai’s other assignments of error were without merit); Hall v. City of Los Angeles, 697 F.3d 1059, 1067 (9th Cir. 2012) (explaining that the law of the case doctrine “generally pre[c]ludes a court from reconsidering an issue decided previously by the same court or by a higher court in the identical case”). Sanai’s motions to file oversized replacement briefs (Dkt. Nos. 14, 21, 24) are denied. See 9th Cir. R. 32- 2. 2 25-2937  Contrary to Sanai’s argument on appeal, the district court did not abuse its discretion by failing to analyze Sanai’s motion under the six factors outlined in Henson v. Fidelity National Financial, Inc., 943 F.3d 434 (9th Cir. 2019). Although the district court did not explicitly name any of the six Henson factors in its decision, it engaged in the relevant equitable analysis. See Henson, 943 F.3d at 444 (providing that the factors are “well-reasoned principles that should guide c