United States District Court, W.D. Arkansas, Texarkana Division
O. Hickey United States District Judge
a civil rights action filed by Plaintiff pursuant to 42
U.S.C. § 1983. Plaintiff proceeds pro se and
in forma pauperis. The case is before the Court for
preservice screening under the provisions of the Prison
Litigation Reform Act (“PLRA”). Pursuant to the
PLRA, the Court must screen any complaint in which a prisoner
seeks redress from a governmental entity, officer, or
employee of a governmental entity. 28 U.S.C. § 1915A(a).
filed his original Complaint on November 20, 2017, in the
Eastern District of Arkansas. (ECF No. 1). On December 1,
2017, the case was transferred to the Western District,
Texarkana Division. (ECF No. 3). In response to this
Court's order, Plaintiff filed an Amended Complaint on
December 15, 2017. (ECF No. 8). Plaintiff is currently
incarcerated in the Nevada County Jail.
to Plaintiff's Amended Complaint, on October 26, 2017, he
“was arrested and charged with possession of a firearm,
aggravated assault, and discharging a firearm in the city
limits, and [he] didn't have anything to do with
it.” (ECF No. 8). He goes on to state, “I feel
that I'm in jail for false imprisonment, and because of
that, my parole has been violated.” (ECF No. 8).
Plaintiff alleges that, by arresting and holding him,
Defendants and the city of Prescott, Arkansas, violated his
Fourth, Fifth, Eighth, and Fourteenth Amendment rights.
Plaintiff's Amended Complaint does not specify whether he
is suing Defendants in their individual or official
capacities, nor does it specify what relief he is
the PLRA, the Court is obligated to screen the case prior to
service of process being issued. The Court must dismiss a
complaint, or any portion of it, if it contains claims that:
(1) are frivolous, malicious, or fail to state a claim upon
which relief may be granted; or (2) seeks monetary relief
from a defendant who is immune from such relief. 28 U.S.C.
is frivolous if “it lacks an arguable basis either in
law or fact.” Neitzke v. Williams, 490 U.S.
319, 325 (1989). A claim fails to state a claim upon which
relief may be granted if it does not allege “enough
facts to state a claim to relief that is plausible on its
face.” Bell Atl. Corp. v. Twombly, 550 U.S.
544, 570 (2007). “In evaluating whether a pro
se plaintiff has asserted sufficient facts to state a
claim, we hold ‘a pro se complaint, however
inartfully pleaded . . . to less stringent standards than
formal pleadings drafted by lawyers.'” Jackson
v. Nixon, 747 F.3d 537, 541 (8th Cir. 2014) (quoting
Erickson v. Pardus, 551 U.S. 89, 94 (2007)). Even a
pro se plaintiff must allege specific facts
sufficient to support a claim. Martin v. Sargent,
780 F.2d 1334, 1337 (8th Cir. 1985).
asserts a claim of false imprisonment against
Defendants. This claim, which challenges the validity
of the pending state criminal proceedings against Plaintiff,
is barred under the abstention doctrine articulated in
Younger v. Harris, 401 U.S. 37, 59 (1971).
Younger doctrine “directs federal courts to
abstain from accepting jurisdiction in cases where granting
[equitable relief] would interfere with pending state
proceedings” involving important state interests.
Night Clubs, Inc. v. City of Fort Smith, Ark., 163
F.3d 475, 477 n.1 (8th Cir. 1998). In federal cases like this
one where only damages are sought, “traditional
abstention principles generally require a stay as the
appropriate mode of abstention.” Night Clubs,
Inc., 163 F.3d at 481 (citing Quackenbush v.
Allstate Ins. Co., 517 U.S. 706, 730 (1996)). This is
true “[a]s long as there may be issues which will need
to be determined in federal court.” Yamaha Motor
Corp., U.S.A. v. Stroud, 179 F.3d 598, 604 (8th Cir.
1999). However, a limited exception applies to allow
dismissal under Younger where an award of damages
would require the federal court to first declare a state
statute unconstitutional or to overturn a state court
judgment on a matter of state policy. Night Clubs,
Inc., 163 F.3d at 482. The Younger abstention
doctrine is a reflection of the public policy that disfavors
federal court interference with state judicial proceedings,
and is based on the principles of comity and federalism.
See Ronwin v. Dunham, 818 F.2d 675, 677 (8th Cir.
factors must be determined affirmatively to result in
abstention under Younger: (1) there must be an
ongoing state judicial proceeding which (2) implicates
important state interests, and (3) that proceeding must
afford an adequate opportunity to raise the federal questions
presented. Fuller v. Ulland, 76 F.3d 957, 959 (8th
Cir. 1996). If all three factors are met, the federal court
must abstain unless it detects “bad faith, harassment,
or some extraordinary circumstance that would make abstention
inappropriate.” Middlesex Cnty. Ethics Comm. v.
Garden State Bar Ass'n, 457 U.S. 423, 435 (1982).
This bad faith exception “must be construed narrowly
and only invoked in extraordinary circumstances.”
Aaron v. Target Corp., 357 F.3d 768, 778-79 (8th
Cir. 2004) (internal quotation marks omitted).
Court finds that the Younger abstention doctrine
applies to this case because Plaintiff's claim involves
an ongoing state judicial criminal proceeding against
Plaintiff, the state clearly has an important interest in
enforcing its criminal laws, and Plaintiff has given no
indication that he cannot raise his constitutional claims
during the state criminal proceedings. Conley v.
Hiland, No. 4:15-cv0359-SWW, 2015 WL 4096152, at *1
(E.D. Ark. July 7, 2015). There is also no indication of bad
faith or any other extraordinary circumstance that would make
abstention inappropriate. Because Plaintiff seeks only
monetary damages, traditional abstention practices generally
favor a stay of this case rather than outright dismissal, and
no exceptions apply requiring dismissal. See Night Clubs,
Inc., 163 F.3d at 481. Thus, the Court will stay and
administratively terminate this federal case until the
pending state criminal charges are resolved. See Yamaha
Motor Corp., U.S.A., 179 F.3d at 603-04;
Conley, 2015 WL 4096152, at *1; Dunkin v.
Morales, No. 1:11-cv-0010-JMM, 2011 WL 719016, at *2
(E.D. Ark. Feb. 22, 2011).