Jack Neal, District Attorney, 8th Judicial District v. Honorable Kearney Brim, Judge, 8th Judicial District

506 F.2d 6, 1975 U.S. App. LEXIS 16660
CourtCourt of Appeals for the Fifth Circuit
DecidedJanuary 9, 1975
Docket73-3769
StatusPublished
Cited by12 cases

This text of 506 F.2d 6 (Jack Neal, District Attorney, 8th Judicial District v. Honorable Kearney Brim, Judge, 8th Judicial District) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jack Neal, District Attorney, 8th Judicial District v. Honorable Kearney Brim, Judge, 8th Judicial District, 506 F.2d 6, 1975 U.S. App. LEXIS 16660 (5th Cir. 1975).

Opinion

WISDOM, Circuit Judge:

On September 10, 1973, Judge Kearney Brim, a Texas state district judge, summoned the lawyers at the bar of Sulphur Springs to his court room and announced that he would convene a court of inquiry 1 on September 24 to determine whether the local district attorney, Jack Neal, had acted unlawfully *8 in the conduct of his office. Previously, Judge Brim had criticized policy decisions made by the district attorney, and the two men had frequently disagreed about the administration of justice in the Eighth Judicial District. 2 On September 20, Neal moved that Judge Brim recuse himself because of personal bias and that he ask the presiding justice of his court to appoint another judge to conduct the inquiry. 3 Judge Brim denied the motion. Neal then sought a federal injunction. After a hearing on the merits, the federal court enjoined Judge Brim from presiding at any inquiry into Neal’s conduct of the district attorney’s office and ordered him to request the presiding judge of his court to appoint another judge to conduct the court of inquiry in his stead.

Judge Brim challenges the propriety of this injunction on several grounds. First, he alleges that the federal court does not have jurisdiction because Neal’s complaint does not state a constitutional claim. He also argues that no “special circumstances” justify the granting of an injunction and that there was insufficient evidence that Neal would be deprived of his constitutional rights because of Judge Brim’s personal bias. Although we find that the federal court has jurisdiction over Jack Neal’s claim, we need not reach the other, issues Judge Brim sets forth because we hold that the federal court should have abstained from deciding the federal constitutional issues until the Texas courts have determined Neal’s rights under Texas law.

I.

At the threshold, we must determine whether Jack Neal’s federal complaint states a cause of action under 42 U.S.C. § 1983 4 and whether the federal courts have jurisdiction under 28 U.S.C. *9 § 1343. 5 To state a claim under Section 1983, a plaintiff must allege some deprivation of federal constitutional or legal rights accomplished under color of state law. Neal alleges that he would be deprived of due process if Judge Brim is not disqualified from presiding at this court of inquiry, because an essential element of due process is the right to be heard by an impartial judge. Johnson v. Mississippi, 1971, 403 U.S. 212, 91 S.Ct. 1778, 29 L.Ed.2d 423. The trial court found, as a matter of fact, that “[t]he evidence indisputably discloses much animosity existing between” Brim and Neal and that Judge Brim “harbors much ill will, bias and prejudice against plaintiff as a result of personal and professional disagreements” in regard to Neal’s conduct of his office. In light of the ample evidence of animosity that was adduced at trial, we hold that the trial court’s findings of fact were not clearly erroneous. Fed.R.Civ.P. 52. Indeed, the record clearly shows that Judge Brim was prejudiced against Mr. Neal.

The question Judge Brim puts to us concerns the legal effect to be given this finding of animosity. The Supreme Court has said that due process is offended if a judge participates in a case when he is “so enmeshed in matters involving petitioner as to make it appropriate for another judge to sit”. Johnson v. Mississippi, 1971, 403 U.S. 212, 215-216, 91 S.Ct. 1778, 1780, 29 L.Ed.2d 423 (emphasis supplied). Judge Brim concedes that the tempestuous history of his relations with Jack Neal would preclude his sitting as a judge in any criminal trial in which Jack Neal is a defendant. He contends, however, that a court of inquiry is a purely investigatory proceeding wherein the district or county judge sits only in the role of magistrate and not as a judge. Therefore, Judge Brim argues, an unbiased judge may be desirable in this context, but such a judge is not required as a matter of due process. Whatever the final merit of Judge Brim's argument, we need say only that it is not helpful for purposes of establishing whether the federal courts have jurisdiction.

In determining whether the federal courts have jurisdiction over the civil rights claim stated in Jack Neal’s complaint, we must decide whether those allegations are wholly insubstantial or frivolous. See Bell v. Hood, 1946, 327 U.S. 678, 66 S.Ct. 773, 90 L.Ed. 939, cf. 5 C. Wright & A. Miller, Federal Practice and Procedure § 1350, p. 556. We need not decide the merits of the constitutional issues Neal raises in order to determine that they are not wholly insubstantial or frivolous. We hold, therefore, that the federal courts have jurisdiction in this case.

The next issue we face is whether this case is an appropriate one for application of the abstention principle.

II.

Although the federal courts have a duty to respect a party’s choice of a federal forum for the determination of federal issues, a federal court, in certain extraordinary and limited circumstances, may postpone its decision in order to avoid premature and perhaps unnecessary decision of a serious federal question or to avoid the hazard of unsettling some delicate balance in the area of state-federal relations. See Louisiana Power & Light Co. v. Thibodaux, 1959, 360 U.S. 25, 79 S.Ct. 1070, 3 L.Ed.2d 1058. “Numerous decisions have sanctioned abstention from deciding cases involving a federal constitu *10 tional issue when a state court determination of state law might moot the issue or put the case in a different posture”. 360 U.S. 25, 32-33, 79 S.Ct. 1070, 1075, 3 L.Ed.2d 1058. Apart from the desirability of not reaching unnecessary federal questions, however, federal courts must be sensitive to a state’s special interest in expounding its own law and supervising its own judiciary. The other side of the coin is, of course, that abstention may lead to unnecessary delay, waste, and expense to litigants that may emasculate federal protection of federal rights. England v. Louisiana Medical Examiners, 1964, 375 U.S. 411, 84 S.Ct. 461, 11 L.Ed.2d 440. See also Harrison v. N. A. A. C. P., 1959, 360 U.S. 167, 180, 79 S.Ct. 1025, 3 L.Ed.2d 1152.

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Bluebook (online)
506 F.2d 6, 1975 U.S. App. LEXIS 16660, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jack-neal-district-attorney-8th-judicial-district-v-honorable-kearney-ca5-1975.