Ninth Circuit: Rynearson v. Fergusun

(Rakoff (SDNY) on panel.)

When a person subject to a protective judicial order seeks to challenge the constitutionality of one of the statutes implicated by the order, federal courts are not required to abstain from the question, as the interference with the state criminal proceeding would be indirect and not dispositive.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/09/07/17-35853.pdf