Wiley v. McKenzie

CourtDistrict Court, E.D. Kentucky
DecidedAugust 20, 2025
Docket0:25-cv-00035
StatusUnknown

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

Bluebook
Wiley v. McKenzie, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION AT ASHLAND

CIVIL ACTION NO. 25-35-DLB

ALLEN WILEY III PLAINTIFF

v. MEMORANDUM ORDER

SHAWN MCKENZIE, ET AL. DEFENDANTS

*** *** *** *** On March 24, 2025, Kentucky inmate Allen Wiley III filed a pro se civil rights complaint alleging Eighth Amendment excessive force claims against various officials at the Eastern Kentucky Correctional Complex (“EKCC”) pursuant to 42 U.S.C. § 1983. (Doc. # 1). The Court screened Wiley’s complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A and allowed his claims against some of the defendants to proceed. (Doc. # 6). Defendant Ryan Mullins filed a motion to dismiss the claim against him based on the statute of limitations (Doc. # 21) and Wiley filed a response in opposition (Doc. # 22). Thereafter, the Court learned that Wiley filed a similar § 1983 action in state court in September 2024. The Court directed the defendants to tender a status report regarding the status of Wiley’s state-court lawsuit and the defendants’ position on abstention pursuant to Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 817 (1976). (Doc. # 23). The defendants tendered a status report asserting that the Court should abstain under Colorado River (Doc. # 25) and Wiley filed a response in opposition (Doc. # 27). Most recently, Wiley filed a motion asking the Court to reconsider its screening order dismissing the claims against Defendants Shawn McKenzie and David Vance. (Doc. # 29). The Court considers all of these issues now. I. The defendants’ counsel reports that Wiley filed a similar action in Franklin Circuit Court on September 15, 2024. See Wiley v. McKenzie, et al., 24-CI-1017. On February

6, 2025, the Franklin Circuit Court concluded that venue was improper and ordered that the matter be transferred to Morgan Circuit Court. However, the transfer did not occur. An employee of the Franklin Circuit Clerk’s office informed defendants’ counsel that Wiley’s case file was among numerous records that were destroyed as a result of flooding. (Doc. # 25 at 1-2). The employee contacted the Morgan Circuit Clerk’s Office to determine whether printed copies of the scanned file would be acceptable to effectuate the transfer. While the Court is unaware of the Morgan Circuit Clerk’s decision, the defendants report that the transfer “is in process, but delayed.” Id. at 2. Despite federal courts’ “virtually unflagging obligation” to exercise their jurisdiction,

“considerations of judicial economy and federal-state comity may justify abstention in situations involving the contemporaneous exercise of jurisdiction by state and federal courts.” Romine v. Compuserve Corp., 160 F.3d 337, 339 (6th Cir. 1998) (citing Colorado River, 424 U.S. at 817. However, having fully considered the matter, Court declines to exercise its discretion to abstain from this action under Colorado River. In determining whether abstention is appropriate, the Court must first assess whether this action and the state court action are parallel. See Romine, 160 F.3d at 339 (citing Crawley v. Hamilton County Comm'rs, 744 F.2d 28 (6th Cir.1984)). Having reviewed the record in each case, the Court concludes that Wiley’s state-court lawsuit is parallel to the instant matter. First, contrary to Wiley’s assertion, the state-court action remains pending. Further, “exact parallelism” of the cases is not required; “[i]t is enough if the two proceedings are substantially similar.” Romine, 160 F.3d at 340 (quoting Nakash v. Marciano, 882 F.2d 1411, 1416 (9th Cir.1989)). In each case, Wiley alleges that officials at the EKCC violated his constitutional right to be free from excessive

force during incidents on November 23, 2023 and June 29, 2024. Moreover, the state court complaint includes allegations against eight of the ten defendants named in the federal complaint, plus an additional defendant not named in the federal complaint. See Preferred Care of Delaware v. VanArsdale, 676 F. App’x 388, 394 (6th Cir. 2017) (observing that an additional party in state proceeding did not “upset an otherwise substantial symmetry between a federal and state action”). Having determined that the two actions are parallel, the Court must determine whether it should defer to the concurrent jurisdiction of the state court. The Sixth Circuit has supplied the following list of factors to consider in determining whether abstention is

appropriate: (1) whether the state has assumed jurisdiction over any res or property; (2) whether the federal forum is less convenient to the parties; (3) avoidance of piecemeal litigation . . . (4) the order in which jurisdiction was obtained. . . . (5) whether the source of governing law is state or federal; (6) the adequacy of the state court action to protect the federal plaintiff’s rights; (7) the relative progress of the state and federal proceedings; and (8) the presence or absence of concurrent jurisdiction.

Romine, 160 F.3d at 340-41 (citations omitted). The second, fourth, fifth, and eighth factors weigh in favor of abstention. The events described in the complaint are alleged to have occurred at the EKCC, which is located in Morgan County. Accordingly, the defendants and potential witnesses are likely to be closer to the Morgan County Circuit Court than the federal courthouse in Ashland, which is over 60 miles away from the EKCC. See PaineWebber, Inc. v. Cohen, 276 F.3d 197, 207 (6th Cir. 2001) (observing that this factor relates to “geographical considerations, not to the relative jurisdictional scope of state versus federal courts”). Additionally, Wiley filed the state-court action approximately six months before he filed his complaint in

federal court. And the source of governing law is federal since Wiley alleges constitutional claims against the defendants under 42 U.S.C. § 1983. Finally, concurrent jurisdiction exists in this case as both the state and federal court have jurisdiction to entertain Wiley’s § 1983 claims. The remaining factors are either neutral or weigh against abstention. With respect to the first factor, the court has not assumed jurisdiction over any property. The third factor is neutral, at best. The Sixth Circuit has observed that “[p]iecemeal litigation occurs when different courts adjudicate the identical issue, thereby duplicating effort and potentially rendering conflicting results.” Romine, 160 F.3d at 341 (citation omitted).

However, concurrent litigation alone does not present a danger of piecemeal litigation sufficient to warrant abstention. See Karkas v. McKeown, 783 F. Supp. 1028, 1032 (E.D. Mich. 1992) (observing that “[t]he mere duplicativeness of a parallel state and federal proceeding . . . is insufficient to justify abstention”). As the Sixth Circuit emphasized in Answers in Genesis of Kentucky, Inc. v.

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Bluebook (online)
Wiley v. McKenzie, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wiley-v-mckenzie-kyed-2025.