Watts v. States Attorney Office for Baltimore County

Filing 4

MEMORANDUM OPINION. Signed by District Judge Brendan Abell Hurson on 6/4/2024. (kb3s, Deputy Clerk)(c/m 6.4.24)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
CHRISTOPHER MAUICE WATTS,
Plaintiff,
v.

Civil Action No.: BAH-24-1458

STATE’S ATTORNEY
BALTIMORE COUNTY,

OFFICE

FOR

Defendant.

MEMORANDUM
On May 17, 2024, Plaintiff Christopher Mauice Watts filed a complaint against the “State’s
Attorney Office for Baltimore County” alleging an Assistant State’s Attorney (“ASA”) defamed
him during his bail review. ECF 1. He also moved to proceed in forma pauperis. ECF 2. Watts’s
motion to proceed in forma pauperis shall be granted, and the complaint shall be dismissed for the
reasons stated in this memorandum.
The only named defendant is “State’s Attorney Office for Baltimore County.” ECF 1, at
1. Watts is a pretrial detainee at the Baltimore County Detention Center. See id. at 2. He claims
that an ASA “li[ed] under oath on record” during Watts’s bail review hearing. Watts claims that
the ASA misrepresented that Watts was “backing up 60 years” rather than 30 years “to prevent
[Watts] from getting a bail” and “to paint the picture that [Watts is] some harden[ed] up criminal
that needs to stay in jail.” Id. at 4. Watts asks that his state criminal proceedings be dismissed and
that he be awarded compensatory damages. Id. at 5.
Pursuant to Fed. R. Evid. 201(b), “[t]he court may judicially notice a fact that is not subject
to reasonable dispute because it . . . can be accurately and readily determined from sources whose

accuracy cannot reasonably be questioned.” Watts is currently being held in pre-trial detention on
counts of attempted first degree murder, first and second degree assault, and related firearms
offenses. See State v. Watts, Case No. C-03-CR-23-004590 (Balt. Cty Cir. Ct.). 1 Watts’ trial is
scheduled for October 30, 2024. Id.
Watts’s complaint must be dismissed. First, Watts’s claim that the ASA defamed him is
not a federal claim. Federal courts are courts of limited jurisdiction and “may not exercise
jurisdiction absent a statutory basis.” Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546,
552 (2005). They “have an independent obligation to determine whether subject-matter
jurisdiction exists, even when no party challenges it.” Hertz Corp. v. Friend, 559 U.S. 77, 94
(2010), see also Arbaugh v. Y&H Corp., 546 U.S. 500, 506–07 (2006) (Fed. R. Civ. Proc. 12(b)(1)
authorizes lack of subject-matter jurisdiction to be raised by a party or by a court on its own
initiative at any stage in the litigation). Under the “well-pleaded complaint” rule, the facts showing
the existence of subject matter jurisdiction “must be affirmatively alleged in the complaint.”
Pinkley, Inc. v. City of Frederick, 191 F.3d 394, 399 (4th Cir. 1999) (citing McNutt v. Gen’l Motors
Acceptance Corp., 298 U.S. 178 (1936)). The requirements for invoking diversity jurisdiction
over a state law claim are not met where, as here, all parties are in Maryland. 2

1

See http://casesearch.courts.state.md.us/inquiry (last viewed May 31, 2024).

2

There are other issues besides jurisdiction that make Watts’s complaint susceptible to dismissal.
First, the State’s Attorney Office for Baltimore County, the only named defendant, is not an entity
capable of being sued. See Owens v. Balt. City State’s Att’ys Off., 767 F.3d 379, 395 (4th Cir.
2014). Additionally, though not named as a defendant, the unnamed ASA is likely immune from
suit. See Buckley v. Fitzsimmons, 509 U.S. 259, 277 (1993) (noting that “prosecutors, like all
attorneys, [are] entitled to absolute immunity from defamation liability for statements made during
the course of judicial proceedings and relevant to them”); Imbler v. Pachtman, 424 U.S. 409, 430
(1976); Nero v. Mosby, 890 F.3d 106, 117 (4th Cir. 2018); see also Lee v. Cline, 863 A.2d 297,
305–06 (Md. 2004) (explaining that Maryland common law public official qualified immunity
protects public officials from defamation claims based in negligence).
2

Further, to the extent Watts’s complaint can be read as bringing a federal constitutional
claim, the Younger 3 abstention doctrine “requires a federal court to abstain from interfering in state
proceedings, even if jurisdiction exists,” if there is: “(1) an ongoing state judicial proceeding,
instituted prior to any substantial progress in the federal proceeding; that (2) implicates important,
substantial, or vital state interests; and (3) provides an adequate opportunity for the plaintiff to
raise the federal constitutional claim advanced in the federal lawsuit.” Laurel Sand & Gravel, Inc.
v. Wilson, 519 F.3d 156, 165 (4th Cir. 2008) (formatting omitted); accord United States v. South
Carolina, 720 F.3d 518, 527 (4th Cir. 2013). “Younger is not merely a principle of abstention;
rather, the case sets forth a mandatory rule of equitable restraint, requiring the dismissal of a federal
action.” Williams v. Lubin, 516 F. Supp. 2d 535, 539 (D. Md. 2007) (quoting Nivens v. Gilchrist,
444 F.3d 237, 247 (4th Cir. 2006)).
Criminal prosecutions implicate vital state interests, and Watts has an adequate opportunity
to advance his claims regarding his entitlement to bail and the conduct of the prosecutor through
his state proceedings. See Sprint Communications, Inc. v. Jacobs, 571 U.S. 69, 72 (2013) (“[O]ne
class of cases in which federal-court abstention is required: When there is a parallel, pending state
criminal proceeding . . . .”). Accordingly, Watts’s complaint must be dismissed without prejudice.
A separate Order follows.
/s/
_____________________________
Brendan A. Hurson
United States District Judge

June 4, 2024
________________
Date

3

Younger v. Harris, 401 U.S. 37 (1971).
3