Saiki v. States of Texas and New Mexico

District Court, W.D. Texas·Decided September 17, 2021·No. 3:21-cv-00123·Unknown

Opinion

. IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS EL PASO DIVISION MARK SAIKI, § Plaintiff, § : EP-21-CV-123-DB THES ATES OF TEXAS AND : NEW MEXICO, § efendants. § MEMORANDUM OPINION AND ORDER ark Saiki, a pretrial detainee in the El Paso County (Texas) Jail Annex proceeding pro se and in forma pauperis, alleges in a complaint under 42 U.S.C. § 1983 that the State of Texas is violating his civil rights. Pl.’s Am. Compl. 1, ECF No. 10.' He reports that El Paso police officers arrested him on April 15, 2021 for public intoxication and again on April 19, 2021 for assaulting a police officer. Id. He claims that he remains in pretrial detention undergoing psychiatric evaluations even though courts in Texas and New Mexico have found him competent to stand trial on three prior occasions. Id. He suggests that “health professionals would be much more efficient by subpoenaing prior medical records and updating or supplementing prior works.”| Id. at 2. He argues that the State of Texas has unnecessarily prolonged his detention “under color of law, and he is being intentionally held against his will, and against his constitutional rights.” Id. at 1. He moves for a temporary restraining order. Id. at 3. He also seeks damages for his “unjust incarceration.” Id. INJUNCTIVE RELIEF aiki asks for a temporary restraining order to secure his release from detention. Id. at 3. He argues his continued detention after his arrest assaulting a police officer somehow violates his

' Saiki the State of New Mexico from his suit in his amended complaint.

constitutional rights and justifies his immediate discharge from jail. Id. at 1. nconstitutional conditions of confinement—even conditions that create a risk of serious physical injury, illness, or death—do not warrant a prisoner’s release. Carson v. Johnson, 112 F.3d 818, 820-21 (Sth Cir.1997). Even allegations of mistreatment that amount to cruel and

punishment do not nullify an otherwise lawful incarceration or detention. Cook v. Hanberty, 596 F.2d 658, 660 (5th Cir. 1979). Allegations challenging “the fact or duration of confinement are properly brought in habeas petitions”—not as civil rights complaints. Schipke v. Van Buren, 239 F. App’x 85, 85-86 (5th Cir. 2007) (citing Spina v. Aaron, 821 F.2d 1126, 1127-28 (Sth Cir. 1987)). n Younger v. Harris, 401 U.S. 37 (1971), the Supreme Court explains a federal court must ndt interfere with a pending state criminal prosecution either by injunction or declaratory judgment in the absence of extraordinary circumstances showing a threat of irreparable injury which is both great and immediate. Id. at 53. The Younger doctrine specifically requires a federal court to decline the exercise of jurisdiction over state criminal defendants’ claims when

three cdnditions 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 (Sth Cir. 2012) (citing Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432 (1982)) (internal citations omitted). A “[p]etitioner must satisfy the Younger abstention hurdles before [a

_ court] may give habeas relief.” Kolski v. Watkins, 544 F.2d 762, 766 (Sth Cir. 1977). This precludes “the derailment of a pending state proceeding by an attempt to litigate constitutional

defenses [to state charges] prematurely in federal court.” Braden v. 30th Jud. Cir. Ct. of Kentucky, 410 U.S. 484, 493 (1973). aiki is scheduled for trial on January 14, 2022 in case number 20210D01018 in the 384th Competency Court of El Paso County for allegedly assaulting a police officer. “The state has a strong interest in enforcing its criminal laws.” DeSpain v. Johnston, 731 F.2d 1171, 1176 : (1984). If convicted, Saiki will have the opportunity to appeal the trial court’s decision. Saiki may still raise and resolve his constitutional challenges in his state-court proceedings. Granting Saiki injunctive relief now may interfere with the state courts’ ability to conduct their criminal proceedings and resolve his claims. As a result, Saiki cannot satisfy the Younger abstention hurdlesjas a precondition to obtaining habeas relief. he Court has, for these reasons, already denied Saiki’s request for immediate release □ through a petition for a writ of habeas corpus. Saiki v. Texas, No. EP-21-CV-126-DB, 2021 WL 3633900, at *2 (W.D. Tex. July 13, 2021). The Court will, for these reasons, also deny his request|for injunctive relief in his civil rights case. DAMAGES aiki argues the State of Texas has unnecessarily prolonged his detention “under color of law, and he is being intentionally held against his will, and against his constitutional rights.” PL’s Am. Compl. 1. He seeks damages for his “unjust incarceration.” Id. at 3. ‘[T]he Prison Litigation Reform Act of 1995 (PLRA) . . . mandates early judicial screening of prisoner complaints.” Jones v. Bock, 549 U.S. 199, 202 (2007) (citing 42 U.S.C. § 1997e)| The screening provisions in 28 U.S.C. § 1915(e}—applicable to plaintiffs proceeding in forma pauperis—require the sua sponte dismissal of an action before responsive pleadings are

filed if the Court finds the complaint is (1) frivolous, (2) malicious, (3) fails to state a claim upon which relief may be granted, or (4) seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(B)@)-fiii). he Magistrate Judge to whom the Court referred this matter screened Saiki’s complaint pursuant to 28 U.S.C. § 1915. R. & R. 3-6, ECF No. 9. She observed “‘[(t]he Eleventh Amendment to the United States Constitution bars suits in federal court by citizens of a state

! against their own state or a state agency or department.’” Id. at 4 (quoting Delahoussaye v. City of NewlIberia, 937 F.2d 144, 146 (Sth Cir. 1991) (quoting Voisin’s Oyster House, Inc. v. Guidry, | 799 F.2d 183, 185 (Sth Cir. 1986))). She noted “there is no evidence that the State of Texas has ‘unequivocally’ consented to the instant suit.” Id. at 5 (citing Pennhurst State Sch. & Hosp. v.

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Saiki v. States of Texas and New Mexico, (W.D. Tex. 2021).

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