Jason A. Fulton v. Stephanie Smith, et al.

Summary

The United States District Court for the District of Kansas directs a pro se plaintiff to show cause why his § 1983 action concerning a disputed state-court docket entry should not be dismissed. The court explains that the requested preservation and record-investigation relief may be moot, may constitute mandamus relief against state officials, and may be subject to Younger abstention. The order grants the plaintiff until June 5, 2026, to respond.

Holdings

1. Federal courts have no authority to issue a writ of mandamus directing state courts or their judicial officers in the performance of their duties.
2. The Ex parte Young exception to sovereign immunity does not eliminate the need to determine whether Younger abstention bars federal injunctive or declaratory relief interfering with ongoing state criminal proceedings.

Questions Presented

1. Whether Plaintiff's request for prohibitory preservation relief is moot because the relevant data has been preserved and is not at risk of deletion, purging, or overwriting.
2. Whether Plaintiff's requested injunctive relief is in the nature of mandamus directed at state officers.
3. Whether Younger abstention requires dismissal of any remaining claims because Plaintiff is pursuing the same relief in ongoing state proceedings.

Disposition

other