LONGS BEY
v.
SCOTT
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A pro se plaintiff filed suit in federal court seeking to enjoin a state court judge from proceeding in criminal proceedings against him, claiming conflict of interest and judicial misconduct. The federal court dismissed the case without prejudice for lack of subject matter jurisdiction under the Younger abstention doctrine, finding the plaintiff failed to allege extraordinary circumstances required for federal intervention in ongoing state proceedings.
The federal court must abstain from exercising jurisdiction under the Younger abstention doctrine because the plaintiff failed to allege the extraordinary circumstances required for federal intervention in state court proceedings: bad faith prosecution, irreparable injury if abstention is exercised, and the absence of an adequate alternative state forum to raise constitutional issues.
[1] Federal courts must abstain from deciding issues implicated in an ongoing criminal proceeding in state court absent extraordinary circumstances.
[2] Federal courts should abstain from granting declaratory or injunctive relief affecting a state criminal proceeding unless the plaintiff demonstrates bad faith prosecution…
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Join FLexlaw to unlock all legal intelligence“[i]n the interest of comity, federal courts abstain from becoming involved in [ ] state court proceeding[s] with few exceptions.”
Establishes the general principle that federal courts should not interfere with state court proceedings
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Join FLexlaw to unlock all legal intelligenceMichael James Longs Bey, proceeding pro se, filed suit against Judge Monique Scott in federal court. Longs Bey was charged with misdemeanor trespass i…
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This matter is before the Court sua sponte on Plaintiff Michael James Longs Bey's complaint filed on July 11, 2025. (Doc. 1). Plaintiff filed this suit against Judge Monique Scott to enjoin state court proceedings against him. Because Plaintiff is proceeding pro se, the Court more liberally construes the pleadings. See Alba v. Montford, 517 F. 3d 1249, 1252 (11th Cir. 2018).
In his emergency petition for a writ of prohibition, Plaintiff moves the Court to bar Judge Scott from proceeding in any further judicial proceedings or actions against him, claiming that there is a conflict of interest, that he did not consent to any trial, that future proceedings would constitute judicial misconduct, and that he has a right to a neutral and non-conflicted tribunal.
"[I]n the interest of comity, federal courts abstain from becoming involved in [] state court proceeding[s] with few exceptions.” Cruz v. Gee, No. 8:13-cv-763-T-30TBM, 2013 WL 1278952, at *1 (M.D. Fla. Mar. 28, 2013) (quoting Pennzoil v. Texaco, Inc., 481 U.S. 1, 14 (1987)). Importantly, “[a]bsent extraordinary circumstances, a federal court must abstain from deciding issues implicated in an ongoing criminal proceeding in state
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court." Id. (quoting Thompson v. Wainwright, 714 F. 2d 1495, 1502 (11th Cir. 1983); see Hughes v. Attorney General of Florida, 377 F. 3d 1258, 1263 n.6 (11th Cir. 2004) (explaining that federal courts should abstain from granting declaratory of injunctive relief affecting a state criminal proceeding absent a showing of: (1) bad faith prosecution, (2) irreparable injury if abstention is exercised, and (3) the absence of an adequate alternative state forum to raise constitutional issues).
To the extent Plaintiff challenges any ongoing state court proceedings, Plaintiff does not allege bad faith prosecution, irreparable injury, or the absence of an adequate state forum where constitutional issues can be raised. Consequently, under Younger, the Court must abstain. [fn 1]
Accordingly, it is
ORDERED, ADJUDGED, and DECREED:
(1) Plaintiff's emergency complaint (Doc. 1) is DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction.
(2) The Clerk is directed to terminate any pending motions and deadlines, and thereafter close this case.
DONE and ORDERED in Chambers in Tampa, Florida, this 11th day of July, 2025.
TOM BARBER UNITED STATES DISTRICT JUDGE
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[fn 1]: To the extent Plaintiff specifically challenges any proceedings in case 25-cm-004155A, it appears that Plaintiff lacks standing. In that case, Plaintiff was charged with misdemeanor trespass. Although a jury trial was set for July 14, 2025, the State of Florida entered a notice of nolle prosequi on July 11, 2025. This notice terminates the case, so there is no active case or controversy as to the requests for declaratory or injunctive relief.
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Longs Bey v. Scott, 2013 WL 1278952 (M.D. Fla. 2025)…t, and that he has a right to a neutral and non-conflicted tribunal. "[I]n the interest of comity, federal courts abstain from becoming involved in [] state court proceeding[s] with few exceptions.” Cruz v. Gee, No. 8:13-cv-763-T-30TBM, 2013 WL 1278952, at *1 (M.D. Fla. Mar. 28, 2013) (quoting Pennzoil v. Texaco, Inc., 481 U.S. 1, 14 (1987)). Importantly, “[a]bsent extraordinary circumstances, a federal court must abstain from deciding issues implicated in an ongoing criminal proceeding in…1 / 2
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Cruz v. Sec'y, Dep't of Corr. (M.D. Fla. 2020)…o immunity under the Florida “stand your ground statute.” (H1). This Court dismissed the petition without prejudice because Petitioner failed to show why his claims could not be reviewed in state court. (H2); Cruz v. Gee, No. 8:13-cv-763-T-30TBM, 2013 WL 1278952 (M.D. Fla. Mar. 28, 2013). Upon remand from the federal habeas detour, Petitioner entered a negotiated guilty plea back in state court. On March 22, 2013, he pled to the reduced charge of manslaughter with a firearm in exchange for a prison sente…
Authorities Cited
- Alba v. Montford, 517 F.3d 1249 (11th Cir. 2008)
- Hughes v. Attorney General OF Florida, 377 F.3d 1258 (11th Cir. 2004)
- Thompson v. Louie L. Wainwright, 714 F.2d 1495 (11th Cir. 1983)
- Longs Bey v. Scott, 2013 WL 1278952 (M.D. Fla. 2025)