Bozarth v. Meadow Valley Justice Court

District Court, D. Nevada·Decided October 23, 2023·No. 2:22-cv-01229·Unknown

Opinion

2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 * * * 6 EDDIE RAY GEORGE WASHINGTON Case No. 2:22-cv-01229-MMD-NJK 7 BOZARTH, ORDER 8 Petitioner, 9 v. 10 MEADOW VALLEY JUSTICE COURT, et 11 al., 12 Respondents. 13 14 15 Before the Court is Plaintiff Eddie Ray George Washington Bozarth’s Objection 16 to Magistrate Judge Order or Ruling under LR IB 3-1 (ECF No. 17) and his counsel’s 17 Motion to Withdraw (ECF No. 22). The Court overrules Bozarth’s objection, grants 18 counsel’s motion to withdraw, and dismisses this action without prejudice because 19 federal abstention is required. 20 I. BACKGROUND 21 In July 2022, Bozarth initiated this matter while detained pretrial at the Lincoln 22 County Detention Center (“LCDC”) on state criminal charges. (ECF No. 1-1.) He filed a 23 complaint against the LCDC, Judge Mike Cowley, Meadow Valley Justice Court, and 24 the bailiffs in court alleging that he was denied access to evidence, denied his 25 constitutional rights, as well as denied the ability to represent himself. (Id. at 3, 5.) In his 26 complaint, he further alleges, inter alia, ineffective assistance of counsel and 27 prosecutorial misconduct. (Id. at 4.) 28 Because Bozarth did not properly commence this action by either paying the 2 the Court instructed Bozarth to pay the filing fee or file a fully complete IFP application. 3 (ECF No. 4.) Bozarth filed an incomplete IFP application (ECF Nos. 5,9) and the Court 4 again instructed Bozarth to pay the filing fee or file a fully complete IFP application. 5 (ECF Nos. 7, 11.) The Court, however, vacated the deadline to file a complete IFP 6 application because Bozarth indicated that the state court found Bozarth to be 7 incompetent and that he was being transferred to the State’s medical facility. (ECF Nos. 8 12, 13.) 9 Before being transferred to the forensic hospital for competency restoration, 10 Bozarth filed a petition for writ of habeas corpus under § 2254 seeking release from 11 custody. (ECF No. 15.) The Court appointed counsel and informed Bozarth that he 12 cannot pursue both civil rights claims under 42 U.S.C. § 1983 and habeas corpus 13 claims under § 2254 in the same case. (ECF No. 16.) The Court instructed counsel to 14 file a notice indicating whether Bozarth: (1) wishes to pursue his § 1983 civil rights 15 complaint and strike his habeas petition in this case; or (2) wishes to strike his § 1983 16 civil rights complaint and pursue his habeas petition in this case. (Id. at 2.) 17 Bozarth filed an objection following Magistrate Judge Koppe’s order appointing 18 counsel and instructing Bozarth to indicate whether he wishes to pursue either his § 19 1983 civil rights complaint or habeas petition in this case. (ECF No. 17.) Counsel for 20 Bozarth filed a motion to withdraw as Bozarth’s attorney. (ECF No. 22.) 21 II. DISCUSSION 22 A. Objection to Magistrate Judge Order or Ruling 23 Magistrate judges are authorized to resolve pretrial matters subject to district 24 court review under a “clearly erroneous or contrary to law” standard. 28 U.S.C. § 25 636(b)(1)(A); Fed. R. Civ. P. 72(a) (“[A] district judge . . . must consider timely 26 objections and modify or set aside any part of the order that is clearly erroneous or is 27 contrary to law.”); see also LR IB 3-1(a). A magistrate judge’s order is “clearly 28 erroneous” if the court has a “definite and firm conviction that a mistake has been 2 contrary to law when it fails to apply or misapplies relevant statutes, case law, or rules 3 of procedure.” Jadwin v. Cnty. of Kern, 767 F.Supp. 2d 1069, 1110-11 (E.D. Cal. 2011) 4 (citation omitted). When reviewing the order, however, the magistrate judge “is afforded 5 broad discretion, which will be overruled only if abused.” Columbia Pictures, Inc. v. 6 Bunnell, 245 F.R.D 443, 446 (C.D. Cal. 2007). 7 In his objection, Bozarth provides that he does not “waive [his] right to direct or 8 control [his] case,” and that he “will remain in control of my case accepting assistance of 9 counsel, but not removing my rights to defend myself.” (ECF No. 17 at 1.) He further 10 provides that he objects to the delays in service to Defendants. (Id.) Although he asserts 11 that he objects to “the inclusion of the §2254 action in this case, which was not [his] 12 intention,” he also provides that it does not make sense that he must “choose between 13 the protections of the law.” (Id. at 2.) Bozarth further appears to reassert his allegations 14 that the state court has denied him access to evidence. (Id.) 15 Bozarth’s objection is unclear and does not assert that Magistrate Judge Koppe’s 16 order was clearly erroneous or contrary to law. To the extent that Bozarth objects to 17 Magistrate Judge Koppe’s order appointing counsel and instructing Bozarth to indicate 18 whether he wishes to pursue either his § 1983 civil rights complaint or habeas petition in 19 this case, the Court overrules his objection. See Nettles v. Grounds, 830 F.3d 922, 927 20 (9th Cir. 2016) (reiterating that “habeas is the exclusive vehicle for claims brought by 21 state prisoners that fall within the core of habeas, and such claims may not be brought 22 in a § 1983 action”); Wilkinson v. Dotson, 544 U.S. 74, 81-82 (2005) (holding that “a 23 state prisoner’s § 1983 action is barred (absent prior invalidation)—no matter the relief 24 sought (damages or equitable relief), no matter the target of the prisoner’s suit (state 25 conduct leading to conviction or internal prison proceedings)—if success in that action 26 would necessarily demonstrate the invalidity of confinement or duration”); see also 18 27 U.S.C § 3006A(a)(2)(B) (authorizing appointment of counsel “when the interests of 28 justice so require”). 2 Upon review of the record, the Court finds that this action is subject to substantial 3 defects. The comity-based Younger abstention doctrine prevents federal courts from 4 interfering with pending state court criminal proceedings by granting injunctive or 5 declaratory relief, even if there is an allegation of a constitutional violation, unless there 6 is an extraordinary circumstance that creates a threat of irreparable injury. Younger, 401 7 U.S. 37, 53-54 (1971). The United States Supreme Court has instructed that "federal- 8 court abstention is required" when there is "a parallel, pending state criminal 9 proceeding." Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69, 72 (2013); Gilbertson v. 10 Albright, 381 F.3d 965 (9th Cir. 2004) (federal courts generally abstain from granting 11 any relief that would interfere with pending state judicial proceedings). Injuries are 12 irreparable only if the threat to a petitioner's federally protected rights cannot be 13 eliminated through his defense of the criminal case. Younger, 401 U.S. at 46. 14 Younger generally requires that federal courts refrain from enjoining or otherwise 15 interfering with ongoing state criminal proceedings if three conditions are met: (1) state 16 judicial proceedings are ongoing, (2) the state proceedings implicate important state 17 interests, and (3) the plaintiff has the opportunity to raise his federal constitutional 18 concerns in the ongoing proceedings. Middlesex Cnty. Ethics Comm. v. Garden State 19 Bar Ass’n, 457 U.S. 423

Free access — add to your briefcase to read the full text and ask questions with AI

Bozarth v. Meadow Valley Justice Court, (D. Nev. 2023).

Bozarth v. Meadow Valley Justice Court (Bozarth v. Meadow Valley Justice Court) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Huffman v. Pursue, Ltd.
420 U.S. 592 (Supreme Court, 1975)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
Canatella v. California
404 F.3d 1106 (Ninth Circuit, 2005)
Ernest Lee Allen v. Art Calderon
408 F.3d 1150 (Ninth Circuit, 2005)
Jadwin v. County of Kern
767 F. Supp. 2d 1069 (E.D. California, 2011)
Damous Nettles v. Randy Grounds
830 F.3d 922 (Ninth Circuit, 2016)
Jason Lee Harris v. J. Kenneth Mangum
863 F.3d 1133 (Ninth Circuit, 2017)
Erick Arevalo v. Vicki Hennessy
882 F.3d 763 (Ninth Circuit, 2018)
Sprint Commc'ns, Inc. v. Jacobs
134 S. Ct. 584 (Supreme Court, 2013)
Gilbertson v. Albright
381 F.3d 965 (Ninth Circuit, 2004)