McChester v. Hemingway

CourtDistrict Court, E.D. Michigan
DecidedJanuary 4, 2022
Docket2:21-cv-12175
StatusUnknown

This text of McChester v. Hemingway (McChester v. Hemingway) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McChester v. Hemingway, (E.D. Mich. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

KRISTOPHER McCHESTER,

Plaintiff, v. CASE NO. 21-cv-12175

JODI HEMINGWAY, HONORABLE VICTORIA A. ROBERTS TABITHA MARIE MARSH, GREGORY CORA, GENESEE COUNTY 67TH DISTRICT ADMINISTRATION, and FNU BAYETT,

Defendants. _________________________________/

OPINION AND ORDER SUMMARILY DISMISSING THE COMPLAINT

I. Introduction

This matter came before the Court on a pro se civil rights complaint. Plaintiff Kristopher McChester alleges that he is confined in a cell in Flint, Michigan. (ECF No. 1, PageID.2.) The address that Plaintiff provides for himself is that of the Genesee County Sheriff. The Court assumes from the address and Plaintiff’s allegations that he is an inmate at the Genesee County Jail. The defendants are Jodi Hemingway, Tabitha Marie Marsh, Gregory Cora, the Genesee County 67th District Administration, and someone with the surname Bayett. (Id. at PageID.1-4.)1 Jodi Hemingway is an attorney licensed to practice law in Michigan, and Tabitha Marie Marsh is a Genesee County District Court judge

in Flint, Michigan. See www.michbar.org.2 Plaintiff describes defendant Gregory Cora as an “unnecessary adjudicator” in Flint and defendant Bayett as a “rights violator” in Flint. (ECF No. 1, PageID. 3-4.)

In the body of his complaint, Plaintiff alleges that he was arrested on January 20, 2021, and that many of the charges stemmed from an illegal search and seizure. (Id. at PageID.7-9.) On February 20, 2021, the Genesee County District Court Administration appointed Ms. Hemingway to represent him in the criminal case, and

he was arraigned. (Id. at PageID.7.) Plaintiff seems to be saying that defendant Cora maintained the register of actions in the case. (Id.) Plaintiff also contends that Ms. Hemingway deprived him of his right to effective assistance of counsel, and that

Judge Marsh neglected to provide him with a timely preliminary examination. (Id. at PageID.6-8.) Plaintiff seeks $21,000,000 in money damages for the alleged violation of his constitutional rights during the criminal proceedings and because he caught the

1 Defendant Bayett is not listed as a defendant in the caption for Plaintiff’s complaint. Nor is Bayett listed as a defendant on the docket for this case. However, he or she is shown as “Defendant No. 5” in the complaint. See ECF No. 1, PageID.4.

2 Use the “Attorney Search” feature on the home page or go to “For Members” and then “Member Directory.” coronavirus while jailed on the criminal charges. (Id. at PageID.9.) Plaintiff also seeks injunctive relief. He wants his vehicle returned to him and the criminal charges

dismissed. (Id.) II. Discussion A. Legal Framework

The Court must screen new complaints and summarily dismiss any complaints that are frivolous or malicious, that fail to state a claim for which relief can be granted, or that seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) and 1915A. Although a complaint “does not

need detailed factual allegations,” the “[f]actual allegations must be enough to raise a right to relief above the speculative level on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Bell Atl. Corp. v. Twombly, 550

U.S. 544, 555-56 (2007) (footnote and citations omitted). In other words, “a complaint must contain sufficient factual matter . . . to ‘state a claim that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual

content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). A complaint is frivolous if it lacks an arguable basis in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). The term “frivolous” in § 1915, “embraces

not only the inarguable legal conclusion, but also the fanciful factual allegation.” Id. Plaintiff appears to bring his complaint under 42 U.S.C. § 1983, which “makes ‘liable’ ‘[e]very person’ who ‘under color of’ state law ‘subjects, or causes to be

subjected,’ another person ‘to the deprivation of any rights, privileges, or immunities secured by the Constitution[.]’ ” Pineda v. Hamilton Cty., Ohio, 977 F.3d 483, 489 (6th Cir. 2020) (quoting the statute) (brackets in original). A plaintiff must prove two things to prevail in an action under § 1983: “(1) that he or she was deprived of

a right secured by the Constitution or laws of the United States; and (2) that the deprivation was caused by a person acting under color of law.” Robertson v. Lucas, 753 F.3d 606, 614 (6th Cir. 2014).

B. Application of the Law 1. Abstention As noted above, Plaintiff is attacking state criminal charges against him. Because he is challenging the validity of the charges and his physical confinement,

his claims would be more appropriate in a habeas corpus action, following exhaustion of state remedies. Preiser v. Rodriguez, 411 U.S. 475, 499 n. 14, 500 (1973). A § 1983 action is not a proper remedy for a state prisoner who is

challenging the fact or length of his custody. Id. at 499. Furthermore, in Younger v. Harris, 401 U.S. 37 (1971), “the Supreme Court held that absent ‘bad faith, harassment or any other unusual circumstance,’ federal-

court abstention is appropriate where a plaintiff invokes federal jurisdiction as a basis for obtaining injunctive relief against state-court criminal proceedings.” Squire v. Coughlan, 469 F.3d 551, 555 (6th Cir. 2006) (citing Younger, 401 U.S. at

53–54). There are three requirements for proper invocation of Younger abstention: “(1) there must be on-going state judicial proceedings; (2) those proceedings must implicate important state interests; and (3) there must be an adequate opportunity in the state proceedings to raise constitutional challenges.” Sun Ref. & Mktg. Co. v. Brennan, 921 F.2d 635, 639 (6th Cir. 1990) (citation omitted). “So long as the constitutional claims of respondents can be determined in the state proceedings and so long as there is no showing of bad faith, harassment, or some other extraordinary circumstance that would make abstention inappropriate, the federal courts should abstain.” Middlesex [County Ethics Comm’n v. Garden State Bar Ass’n, 457 U.S. 423, 435 (1982)].

Id.

All three Younger factors are present in this case. First, Plaintiff’s criminal case appears to be pending in state court. Second, his criminal case implicates an important state interest, “as state criminal prosecutions have traditionally been considered an arena in which federal courts decline to interfere.” Leveye v. Metro. Pub. Defender’s Office, 73 F. App’x 792, 794 (6th Cir. 2003) (citing Younger, 401 U.S. at 43–45).

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Related

Bradley v. Fisher
80 U.S. 335 (Supreme Court, 1872)
Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Adron Floyd v. County of Kent
454 F. App'x 493 (Sixth Circuit, 2012)
Savoie v. Martin
673 F.3d 488 (Sixth Circuit, 2012)
Coles v. Granville
448 F.3d 853 (Sixth Circuit, 2006)
Carole R. Squire v. Jonathan E. Coughlan
469 F.3d 551 (Sixth Circuit, 2006)
Tyron Brown v. Lee Lucas
753 F.3d 606 (Sixth Circuit, 2014)
David Agema v. City of Allegan
826 F.3d 326 (Sixth Circuit, 2016)
Daniel Norfleet v. Heather Renner
924 F.3d 317 (Sixth Circuit, 2019)
Ali Pineda v. Hamilton Cty., Ohio
977 F.3d 483 (Sixth Circuit, 2020)
Leveye v. Metropolitan Public Defender's Office
73 F. App'x 792 (Sixth Circuit, 2003)

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Bluebook (online)
McChester v. Hemingway, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcchester-v-hemingway-mied-2022.