Williams v. Brown

CourtDistrict Court, W.D. Arkansas
DecidedJanuary 4, 2021
Docket4:20-cv-04079
StatusUnknown

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

Bluebook
Williams v. Brown, (W.D. Ark. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS TEXARKANA DIVISION

HARMON WILLIAMS PLAINTIFF

v. Civil No. 4:20-cv-04079

DETECTIVE REYN BROWN, et al. DEFENDANTS

ORDER This is a civil rights action filed by Plaintiff pursuant to 42 U.S.C. § 1983. Plaintiff proceeds pro se and in forma pauperis. This case is before the Court for preservice screening under the provisions of the Prison Litigation Reform Act (“PLRA”). Pursuant to 28 U.S.C. § 1915A, the Court has the obligation to screen any complaint in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. I. BACKGROUND Plaintiff filed his Complaint on September 15, 2020. (ECF No. 1). Plaintiff’s Motion for Leave to Proceed In Forma Pauperis (“IFP”) (ECF No. 2) was granted by the Court. (ECF No. 3). An Amended Complaint was filed on October 5, 2020. (ECF No. 9). Plaintiff’s Amended Complaint states two claims. (ECF No. 9). In Plaintiff’s first claim, he names as Defendants Terry Crabtree, Daniel Hampton, Reyn Brown, Daniel Oller, and Stephen Eulick.1 The allegations in Plaintiff’s first claim concerns an incident which occurred on October 15, 2019. Plaintiff states that his work supervisors, Separate Defendants Terry Crabtree and Daniel Hampton, contacted his parole officer, Separate Defendant Stephen Eulick, and that he was

1 Separate Defendant Oller is a police officer with the Hope Police Department and Separate Defendant Reyn Brown is a Detective with the Hope Police Department. While not specifically stated, Defendant indicates that both of these Defendants were at the scene of the incident on October 15, 2019. unlawfully detained and eventually arrested for possession of meth “off false accusations,” a “false investigation,” and with “no probable cause.” (ECF No. 9 at 6). In his second claim, Plaintiff names Sgt. Casey Singleton, Sergeant of Patrol at the Hope Police Department, and Detective Daniel Lauterbach, Detective of the Hope Police Department, as Defendants. (ECF No. 9). Plaintiff argues that on July 1, 2020, he was “picked up” by the above-mentioned officers who claimed that Plaintiff had evaded parole. (ECF No. 9 at 9-10). Plaintiff further states that he is currently serving a six-month sentence for parole violation. (ECF

No. 9 at 12). Plaintiff indicates that he was deprived of due process and equal protection when his parole was revoked without due process of law. (ECF No. 9 at 12). Plaintiff seeks compensatory and punitive damages with respect to both claims. (ECF No. 9 at 14). II. APPLICABLE LAW Under the PLRA, the Court is obligated to screen the case prior to service of process being issued. The Court must dismiss a complaint, or any portion of it, if it contains claims that: (1) are frivolous, malicious, or fail to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). A claim is frivolous if “it lacks an arguable basis either in law or fact.” Neitzke v. Williams,

490 U.S. 319, 325 (1989). A claim fails to state a claim upon which relief may be granted if it does not allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). “In evaluating whether a pro se plaintiff has asserted sufficient facts to state a claim, we hold ‘a pro se complaint, however inartfully pleaded . . . to less stringent standards than formal pleadings drafted by lawyers.’” Jackson v. Nixon, 747 F.3d 537, 541 (8th Cir. 2014) (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007)). However, a pro se Plaintiff must allege specific facts sufficient to support a claim. Martin v. Sargent, 780 F.2d 1334, 1337 (8 Cir. 1985). III. DISCUSSION A. First Claim - Separate Defendants Terry Crabtree and Daniel Hampton Plaintiff seeks to state a claim against Separate Defendants Terry Crabtree and Daniel Hampton, who are both private citizens and were allegedly Plaintiff’s supervisors at his place of employment, Tyson Feed Mill. Neither Crabtree nor Hampton are subject to suit under § 1983. A § 1983 complaint must allege that the defendant, acting under color of state law, deprived plaintiff

of “rights, privileges or immunities secured by the Constitution and laws” of the United States. 42 U.S.C. § 1983; see also DuBose v. Kelly, 187 F.3d 999, 1002 (8th Cir.1999). Crabtree and Hampton are not state actors. Accordingly, Plaintiff’s Amended Complaint should be dismissed with respect to all claims against Separate Defendants Terry Crabtree and Daniel Hampton. B. First Claim – Separate Defendants Reyn Brown, Daniel Oller, and Stephen Eulick As mentioned earlier, Plaintiff’s first claim concerns an October 15, 2019 incident that led to criminal charges for possession of methamphetamine. A criminal case for possession of a controlled substance is currently pending against Plaintiff in Hempstead County, Arkansas. State of Arkansas v. Harmon Williams, Case No. 29CR-19-355. The Court will take judicial notice of

the proceedings in the Circuit Court of Hempstead County, Arkansas. Fed. Evid. R. 201. Plaintiff’s claim of false arrest, as set forth in his first claim, challenges the validity of the pending state criminal proceedings against him and is barred under the abstention doctrine articulated in Younger v. Harris, 401 U.S. 37, 59 (1971). The Younger doctrine “directs federal courts to abstain from accepting jurisdiction in cases where granting [equitable relief] would interfere with pending state proceedings” involving important state interests. Night Clubs, Inc. v. City of Fort Smith, Ark., 163 F.3d 475, 477 n.1 (8th Cir. 1998). The Younger abstention doctrine reflects the public policy that disfavors federal court interference with state judicial proceedings and is based on the principles of comity and federalism. See Ronwin v. Dunham, 818 F.2d 675, 677 (8th Cir. 1987). Three factors must be determined affirmatively to result in abstention under Younger: (1) there must be an ongoing state judicial proceeding which (2) implicates important state interests, and (3) that proceeding must afford an adequate opportunity to raise the federal questions presented. Fuller v. Ulland, 76 F.3d 957, 959 (8th Cir. 1996). If all three factors are met, the

federal court must abstain unless it detects “bad faith, harassment, or some extraordinary circumstance that would make abstention inappropriate.” Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 435 (1982). This bad faith exception “must be construed narrowly and only invoked in extraordinary circumstances.” Aaron v. Target Corp.,

Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Night Clubs, Inc. v. City Of Fort Smith
163 F.3d 475 (Eighth Circuit, 1998)
Aaron v. Target Corporation
357 F.3d 768 (Eighth Circuit, 2004)
Randall Jackson v. Jay Nixon
747 F.3d 537 (Eighth Circuit, 2014)
Tony Newmy, Sr. v. Trey Johnson
758 F.3d 1008 (Eighth Circuit, 2014)
Yamaha Motor Corp. v. Patricia Stroud
179 F.3d 598 (Eighth Circuit, 1999)
Martin v. Sargent
780 F.2d 1334 (Eighth Circuit, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
Williams v. Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-brown-arwd-2021.