SAITO
v.
COLLIER COUNTY MUNICIPAL CORPORATION
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The court held that a stay of civil proceedings is appropriate pending resolution of a related criminal case to serve the interests of the court and parties.
Plaintiffs filed a civil suit against various individuals and entities involved in a traffic stop and subsequent state prosecution. Defendants moved t…
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Lynnea Saito and Koichi Saito, pro se Plaintiffs, have sued several individuals and entities (collectively, “Defendants”) involved, albeit tangentially, in a traffic stop and the state prosecution that followed and is still pending. (Doc. 24). Before the Court is a Motion to Stay filed by Defendants Collier County Sheriff’s Office, Collier County Municipal Corporation, Edward Kelly, Byron Tomlinson, and Charles Nunley (“Defendants”). (Doc. 42). Plaintiffs oppose the motion.1 (Doc. 57).
“The District Court has broad discretion to stay proceedings as an incident to its power to control its own docket.” Clinton v. Jones, 520 U.S. 681, 706 (1997). “[T]he power to stay proceedings is incidental to the power inherent in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936). Determining whether a stay is appropriate “calls for the exercise of judgment, which must weigh competing interests and maintain an even balance.” Id. at 254–55.
When related criminal and civil actions are pending, courts evaluating the need for stay balance several interests, including how the issues in the criminal and civil cases overlap; the status of the criminal case; the interests of the plaintiffs in proceeding expeditiously weighed against the prejudice to plaintiffs caused by the delay; the interests of and burden on the defendants; and the public interest. See Harris v. City of Boynton Beach, No. 9:16-CV- 80148, 2016 WL 3747680, at *2 (S.D. Fla. July 13, 2016).
while the criminal case is proceeding, and they argue the potential consequences to Defendants in proceeding far outweigh any potential prejudice to Plaintiffs caused by a stay. (Doc. 42 at 9). Defendants argue stay would also serve the interests of the public and the judicial system.
(Doc. 42 at 10–12). For example, that resolution of the criminal case would narrow the issues, streamline discovery, increase the possibility of settlement, and that it could raise or strengthen theories of collateral estoppel and qualified immunity, which could be dispositive. (Doc. 42 at 10–
12). The Court is persuaded by Defendants’ arguments and concludes that a stay will best serve the interests of the Court and the parties.
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JOHN L. BADALAMENTI
UNITED STATES DISTRICT JUDGE
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Citator
Authorities Cited
- Landis v. N. Am. Co., 299 U.S. 248 (U.S. 1936)
- Clinton v. Jones, 520 U.S. 681 (U.S. 1997)