Yang v. State of Wisconsin

CourtDistrict Court, E.D. Wisconsin
DecidedOctober 15, 2024
Docket2:24-cv-01200
StatusUnknown

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

Bluebook
Yang v. State of Wisconsin, (E.D. Wis. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

KAY XIONG YANG,

Petitioner, Case No. 24-cv-1200-bhl v.

STATE OF WISCONSIN, et al,

Respondents. ______________________________________________________________________________

SCREENING ORDER ______________________________________________________________________________ On September 20, 2024, Petitioner Kay Xiong Yang, proceeding pro se, filed an “Emergency Petition for Declaratory Judgment with Injunctive Relief,” naming the State of Wisconsin, James K. Meuhlbauer, Kristian Lindo, Adam Y. Gerol, Matthew Seipel, and Does 1– 100 as “Respondents.” (ECF No. 1.) Attached to the filing were more than 300 pages of additional documents, consisting of charging documents, hearing transcripts, and related materials from a state court criminal case. (ECF Nos. 1-2–5.) That same day, Yang filed a “Petition for and Notice of Removal,” by which she seeks to remove to federal court a state criminal case pending against her in Ozaukee County Circuit Court, Case No. 2024CF000031. (ECF No. 2.) Yang also filed an “Emergency Petition for Temporary Restraining Order” in which she asks the Court to halt state court proceedings related to her mental competency. (ECF No. 3.) Yang has paid the civil filing fee, but the Court will nevertheless exercise its authority to screen her petition. See Rowe v. Shake, 196 F.3d 778, 783 (7th Cir. 1999) (citing 28 U.S.C. § 1915(e)(2)(B)). For the reasons given below, the Court will dismiss this action and, to the extent her notice of removal had any temporary effect, summarily remand Yang’s state criminal proceeding to Ozaukee County Circuit Court. ALLEGATIONS Yang’s initial filing, an “Emergency Petition for Declaratory and Injunctive [R]elief,” alleges that Ozaukee County Circuit Judge James K. Meuhlbauer issued a bench warrant against her on September 19, 2024. (ECF No. 1 at 1–2.) The warrant was apparently issued to compel her to sit for a mental evaluation after she failed to comply with the state court’s order in her criminal case, in which she is charged with four counts of criminal slander of title, a Class H felony. (ECF No. 1-2 at 4–5; ECF No. 2-1 at 34.) Yang challenges the warrant on grounds that she was unrepresented by counsel and did not waive her right to counsel on the record when the warrant was issued. (ECF No. 1 at 2.) Her petition includes a number of block quotes from state court documents along with accusations of misconduct against the state court judge. (Id. at 2–8.) Yang attaches 300 pages of state court documents to the filing. (ECF Nos. 1-2–5.) In her petition, she requests “an immediate emergency injunction, and an answer to certain federal questions as to the rights of Petitioner as it relates to her individual rights including but not limited to her being forced to speak in a criminal proceeding without the benefit of counsel.” (Id. at 2.) She provides a list of 19 “Questions Ripe for Declaratory Judgment” and states that she “has presented the 1787 Constitution and the 1789 Bill of Rights as the primary contract to define all her rights and duties, and this is her stipulated choice of Law on the record in the State case.” (Id. at 14.) The questions all pertain to the actions of the state court in her pending criminal matter. (Id. at 14–16.) Yang asks the Court to enter a temporary restraining order under Federal Rule of Civil Procedure 65(b) enjoining the state court from proceeding with her criminal prosecution. (Id. at 17.) She also asks the Court to set a hearing “to answer all of her questions as stated in her sworn and verified complaint, and others that may arise at such hearing.” (Id.) Yang’s second filing, a “Petition for and Notice of Removal,” asks the Court to assume jurisdiction over her state criminal case pursuant to 28 U.S.C. §§ 1331, 1441, and 1446. (ECF No. 2.) As grounds for removal, Yang asserts that the state court has violated her Sixth Amendment right to effective assistance of counsel, Fifth Amendment right against self-incrimination, and Due Process rights under the Fourteenth Amendment. (Id. at 2.) Yang includes with her petition more documents from her state court case. (ECF No. 2-1.) Yang’s third filing, an “Emergency Petition for Temporary Restraining Order,” again alleges that the state court has violated her Fifth, Sixth, and Fourteenth Amendment Rights. (ECF No. 3 at 2.) She asks the Court to issue a temporary restraining order enjoining Respondents from executing the September 19, 2024 bench warrant, having her involuntarily committed without conducting a hearing and establishing good cause, and “[c]onducting any further competency examinations without proper legal procedures and the presence of Petitioner’s chosen counsel.” (Id. at 4.) ANALYSIS Yang’s petitions all include requests that this Court interfere with her state court criminal matter and are therefore barred by Younger v. Harris, 401 U.S. 37 (1971). In Younger, the Supreme Court held that federal courts should generally abstain from hearing cases that would disrupt ongoing state criminal proceedings. Id. at 43–45; see also J.B. v. Woodard, 997 F.3d 714, 722 (7th Cir. 2021)(“[Younger] directs federal courts to abstain from exercising jurisdiction over federal claims that seek to interfere with pending state court proceedings.”). This is true even where a litigant alleges that his or her federal rights are being violated in the state court proceeding. See Younger, 401 U.S. at 46; see also Kugler v. Heflant, 421 U.S. 117, 124 (1975) (“The policy of equitable restraint expressed in [Younger] is founded on the premise that ordinarily a pending state prosecution provides the accused a fair and sufficient opportunity for vindication of federal constitutional rights.”). Exceptions to Younger are “very narrow” and must create “an extraordinarily pressing need for immediate federal equitable relief.” Arkebauer v. Kiley, 985 F.2d 1351, 1358–59 (7th Cir. 1993) (quoting Kugler, 421 U.S. at 125). Younger abstention applies to requests for both injunctive and declaratory relief. Samuels v. Mackell, 401 U.S. 66, 69–74 (1971). Yang’s requests for relief fall directly under Younger. She specifically asks the Court to enjoin an ongoing state criminal prosecution, and she falls well short of establishing an extraordinarily pressing need for the Court to intervene. The record she presents shows Yang is seeking to avoid compliance with a competency examination authorized by statute. (See ECF No. 1-2 at 5.) If she disagrees with the state court’s orders, she can seek reconsideration from that court or file an appeal with the Wisconsin Court of Appeals. Under Younger, it is not the federal court’s role to involve itself in her state criminal proceeding.

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Related

Georgia v. Rachel
384 U.S. 780 (Supreme Court, 1966)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Kugler v. Helfant
421 U.S. 117 (Supreme Court, 1975)
J. B. v. Tiffany Woodard
997 F.3d 714 (Seventh Circuit, 2021)
Indiana v. Haws
131 F.3d 1205 (Seventh Circuit, 1997)

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Bluebook (online)
Yang v. State of Wisconsin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yang-v-state-of-wisconsin-wied-2024.