Bryant Crawford v. City of Dallas

CourtDistrict Court, N.D. Texas
DecidedMay 23, 2025
Docket3:25-cv-01211
StatusUnknown

This text of Bryant Crawford v. City of Dallas (Bryant Crawford v. City of Dallas) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bryant Crawford v. City of Dallas, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

CASSANDRA BRYANT CRAWFORD, § § Plaintiff, § § V. § No. 3:25-cv-1211-X-BN § CITY OF DALLAS, § § Defendant. §

MEMORANDUM OPINION AND ORDER TO STAY AND ADMINISTRATIVELY CLOSE In April 2024, a state court in Dallas County, Texas entered an agreed permanent injunction and final judgment in a lawsuit brought by the City of Dallas against Cassandra Bryant Crawford (the plaintiff who filed this federal lawsuit pro se), Isiah T. Payne, and 3528 Colonial Avenue, Dallas, Texas (Crawford’s address in the pro se complaint) (the “Property”), through which the state court identified Dallas City Code violations at the Property, permanently enjoined a commercial operation and the Property, and ordered that the identified violations at the Property be abated (and a fine be paid) and that that court shall have continuing jurisdiction over the enforcement of the injunction. See City of Dall. v. Crawford, No. DC-23-08770, 134th Jud. Dist. Ct., Dall. Cnty., Tex. (Apr. 12, 2024); cf. Stiel v. Heritage Numismatic Auctions, Inc., 816 F. App’x 888, 892 (5th Cir. 2020) (per curiam) (under Federal Rule of Evidence 201, a district court may “take judicial notice of the state court’s orders, final judgment, and docket as matters of public record” (citations omitted)). That proceeding has remained active since. For example, in March 2025, the state court, after finding that Crawford and Payne violated the final judgment, granted the City’s motion to appoint a receiver of the Property and authorized the receiver to make any reasonable repairs necessary to bring the Property into

substantial compliance with city code. See Crawford, No. DC-23-08770, docket. And, just last week, the state court granted the receiver’s motion to issue a receiver’s certificate of $369,852.15 secured by the Property. See id. Before the state court entered that order, Crawford filed this lawsuit under 42 U.S.C. § 1983 against the City in federal court challenging, among other (but related) things, that amount as unconstitutional. See Dkt. No. 3 at 1 (“The City of Dallas has disregarded due process, ignored Plaintiff’s valid Certificate of Occupancy, and

authorized a receiver to pursue a grossly inflated $369,852.15 budget, including $228,000 for undefined construction and only $2,500 for actual repairs.”). Because Crawford also moved for leave to proceed in forma pauperis (“IFP”), see Dkt. No. 4, United States District Judge Brantley Starr referred this lawsuit to the undersigned United States magistrate judge for pretrial management under 28 U.S.C. § 636(b) and a standing order of reference.

But the Court need not rule on that motion. Because, as the record set out above demonstrates – and the docket in Crawford, No. DC-23-08770, further confirms – this lawsuit invites a federal court to interfere with ongoing state court litigation, and, so, the Court must abstain from exercising its jurisdiction over this case under Younger v. Harris, 401 U.S. 37 (1971), which, “following Pennzoil Co. v. Texaco Inc., 481 U.S. 1, 10-11 (1987), [ ] also applies ‘when certain civil proceedings are pending, if the State’s interests in the proceeding are so important that exercise of the federal judicial power would disregard the comity between the States and the National Government,’” Health Net, Inc. v. Wooley, 534 F.3d 487, 494 (5th Cir. 2008).

Section 1983 provides for a cause of action where it’s alleged that a state actor violated the Constitution or federal law. But that statute “does not ‘qualify in any way the principles of equity, comity, and federalism that must restrain a federal court when asked to enjoin a state court proceeding.’” Gates v. Strain, 885 F.3d 874, 880 (5th Cir. 2018) (quoting Mitchum v. Foster, 407 U.S. 225, 243 (1972); citing Younger, 401 U.S. at 43-47). And, under Younger, a federal court should abstain from exercising its

jurisdiction when to do so would result in the interference in certain, select state proceedings. That is, Younger abstention “applies only to three exceptional categories of state proceedings: ongoing criminal prosecutions, certain civil enforcement proceedings akin to criminal prosecutions, and pending civil proceedings involving certain orders ... uniquely in furtherance of the state courts’ ability to perform their

judicial functions.” Google, Inc. v. Hood, 822 F.3d 212, 222 (5th Cir. 2016) (cleaned up). The doctrine requires that federal courts decline to exercise jurisdiction where three conditions are met: “(1) the federal proceeding would interfere with an ongoing state judicial proceeding; (2) the state has an important interest in regulating the subject matter of the claim; and (3) the plaintiff has an adequate opportunity in the state proceedings to raise constitutional challenges.” Bice v. La. Pub. Defender Bd., 677 F.3d 712, 716 (5th Cir. 2012) (cleaned up); accord Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432 (1982).

And the United States Supreme Court has recognized that Younger abstention is appropriate where a federal plaintiff requests an injunction that would have the practical effect of enjoining state proceedings. See Pennzoil Co., 481 U.S. at 13-14 (“Both Juidice[ v. Vail, 430 U.S. 327 (1977),] and this case involve challenges to the processes by which the State compels compliance with the judgments of its courts. Not only would federal injunctions in such cases interfere with the execution of state judgments, but they would do so on grounds that challenge the very process by which

those judgments were obtained.”); Elna Sefcovic, LLC v. TEP Rocky Mountain, LLC, 953 F.3d 660, 671 (10th Cir. 2020) (“[B]oth Juidice and Pennzoil involved requests to directly or indirectly thwart state court compliance processes.” (citing Joseph A. ex rel. Corrine Wolfe v. Ingram, 275 F.3d 1253, 1272 (10th Cir. 2002) (“Younger governs whenever the requested relief would interfere with the state court’s ability to conduct proceedings, regardless of whether the relief targets the conduct of a proceeding

directly.”); Zeeco, Inc. v. JPMorgan Chase Bank, Nat’l Ass’n, No. 17-CV-384-JED- FHM, 2017 WL 6539504, at *2 (N.D. Okla. Dec. 21, 2017) (“What Younger, Juidice, and Pennzoil have in common is that they all involved plaintiffs filing separate federal suits in an attempt to enjoin ongoing state proceedings.”))). And the additional Middlesex County factors are present here: “In this case, the state proceedings are judicial in nature and represent important state interests, as state courts must be empowered to enforce their own orders and judgments.

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Related

Mire v. Full Spectrum Lending Inc.
389 F.3d 163 (Fifth Circuit, 2004)
Health Net, Inc. v. Wooley
534 F.3d 487 (Fifth Circuit, 2008)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Juidice v. Vail
430 U.S. 327 (Supreme Court, 1977)
Moore v. Sims
442 U.S. 415 (Supreme Court, 1979)
Pennzoil Co. v. Texaco Inc.
481 U.S. 1 (Supreme Court, 1987)
Bice v. Louisiana Public Defender Board
677 F.3d 712 (Fifth Circuit, 2012)
Google, Incorporated v. James Hood, III
822 F.3d 212 (Fifth Circuit, 2016)
Shane Gates v. Rodney Strain
885 F.3d 874 (Fifth Circuit, 2018)
Elna Sefcovic v. TEP Rocky Mountain
953 F.3d 660 (Tenth Circuit, 2020)
Joseph A. ex rel. Corrine Wolfe v. Ingram
275 F.3d 1253 (Tenth Circuit, 2002)
Mitchum v. Foster
407 U.S. 225 (Supreme Court, 1972)

Cite This Page — Counsel Stack

Bluebook (online)
Bryant Crawford v. City of Dallas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryant-crawford-v-city-of-dallas-txnd-2025.