669. Younger had established a firm rule against enjoining ongoing state criminal proceedings, absent exceptional circumstances, and the plaintiffs in O’Shea simply sought to “indirectly accomplish the [same] kind of interference” through an “ongoing federal audit” of state proceedings. Id. at 500, 94 S.Ct. 669. The Supreme Court later relied on the principles of O’Shea to hold that an injunction requiring the Philadelphia police department to draft comprehensive internal procedures to address civilian complaints was beyond the “scope of federal equity power.” See Rizzo v. Goode, 423 U.S. 362, 378-80, 96 S.Ct. 598, 46 L.Ed.2d 561 (1976). Younger has also been extended well beyond criminal proceedings. See, e.g., Gilbertson v. Albright, 381 F.3d 965, 968-69 (9th Cir.2004) (en banc) (<HOLDING>); Wiener v. Cnty. of San Diego, 23 F.3d 263,
holding that equitable principles apply to child support proceedings holding that equitable tolling principles apply to suits against the united states in the same manner as they apply to private parties holding that younger principles apply to an action for damages that relates to a pending state proceeding holding that younger abstention is jurisdictional holding that challenge to state proceeding was barred by younger even if it was not barred by rookerfeldman