Jerome Collins v. CPL Clancy, et al.

Summary

The United States District Court for the District of Delaware screened a pro se prisoner's 42 U.S.C. § 1983 complaint concerning alleged falsification of a police report and improper prosecution while state criminal charges were pending. The court dismissed the complaint without prejudice under the Younger abstention doctrine, denied as moot the motion for body-camera footage, and closed the case.

Holdings

1. Younger abstention applies because Collins's state criminal proceeding is ongoing and judicial in nature, implicates important state interests, and provides an adequate opportunity to raise his federal concerns; therefore, the federal court must not interfere with the prosecution absent extraordinary circumstances.
2. The complaint must be dismissed without prejudice under the Younger abstention doctrine at the preliminary screening stage.

Questions Presented

1. Whether the court should abstain under Younger from exercising jurisdiction over Collins's request to enjoin an ongoing Delaware criminal prosecution.
2. Whether the complaint should be dismissed during statutory screening under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b).

Disposition

dismissed