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MacDonald v. James

United States District Court, W.D. Arkansas, Texarkana Division

March 9, 2018

OFFICER D. JAMES, Texarkana Police Department; and OFFICER VANMETER, Texarkana Police Department DEFENDANTS



         This is 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 28 U.S.C. § 1915A, the Court has the obligation to screen any complaint in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.

         I. BACKGROUND

         Plaintiff filed his Complaint on February 23, 2018. (ECF No. 1). Plaintiff's Complaint alleges that Defendants D. James and Vanmeter (hereinafter “Defendants”) arrested him on August 20, 2018, [1] without cause, which resulted in his incarceration for 176 days. (ECF No. 1, p. 3). Plaintiff further alleges that Defendants:

arrested unfairly falsely without being read my Miranda rights I believe 1) these officers intended to arrest confine myself 2) I was aware of confinement, 3) I did not consent to confinement, 4) This confinement is not privileged…This false arrest has caused me numerous hours of pain and suffering…

         (ECF No. 1, pp. 4-5). Plaintiff's Complaint does not state whether he is suing Defendants in their individual or official capacities. Plaintiff alleges that he is entitled to compensatory and punitive damages. Plaintiff further requests injunctive relief, stating that he is “seeking harassment claims as to file a restraining order against these officers in lieu of the constant use of emc ‘electromagnetic' mind control weapons which are not available to civilians but by only officers of agencies.” (ECF No. 1, p. 7).


         As previously stated, the PLRA requires the Court to screen cases prior to service of process being issued. Plaintiff asserts a claim of false arrest 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).[2]

         The 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). 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. 1987).

         Three 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).

         The 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 monetary damages and injunctive relief, the Younger abstention doctrine favors dismissal. See Night Clubs, Inc., 163 F.3d at 481.


         For the foregoing reasons, Plaintiff's Complaint (ECF No. 1) is hereby DISMISSED

         WITHOUT ...

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