United States District Court, W.D. Arkansas, Texarkana Division
ROY N. MACDONALD PLAINTIFF
OFFICER D. JAMES, Texarkana Police Department; and OFFICER VANMETER, Texarkana Police Department DEFENDANTS
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 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
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,  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…
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).
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).
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).
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 monetary
damages and injunctive relief, the Younger
abstention doctrine favors dismissal. See Night Clubs,
Inc., 163 F.3d at 481.
foregoing reasons, Plaintiff's Complaint (ECF No. 1) is