Harris v. City of Willoughby, Municipal Court, Inc.
Filing
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Memorandum Opinion and Order: For the reasons stated herein, all proceedings in this case are stayed pending the conclusion of Kirtland v. Harris, No. 23TRD05715 (Willoughby Mun. Ct. filed Nov. 6, 2023), including all appeals. This case is administratively closed, subject to reopening upon written motion to reopen filed by Plaintiff demonstrating the Municipal Court case listed above and all appeals in that case has been resolved or concluded. No claims or defenses are waived because of the stay. All pending motions are denied without prejudice subject to refiling in the event the case is reopened. IT IS SO ORDERED. Judge Bridget Meehan Brennan on 1/28/25. (T,A)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
ROBERT HARRIS,
Plaintiff,
v.
CITY OF WILLOUGHBY
MUNICIPAL COURT,
Defendant.
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CASE NO. 1:24-CV-1946
JUDGE BRIDGET MEEHAN. BRENNAN
MEMORANDUM OPINION
AND ORDER
Pro se Plaintiff Robert Harris brings this action to challenge a traffic citation he received
from the City of Kirtland for failing to display a valid license plate. See Kirtland v. Harris, No.
23TRD05715 (Willoughby Mun. Ct. filed Nov. 6, 2023).1 Plaintiff claims the City of
Willoughby subjected him to an unreasonable search and seizure when its officers stopped him
and cited him for driving a vehicle with fictitious plates. He contends that municipalities can
only enforce vehicle license and registration statutes on commercial vehicles. He claims he was
driving a private vehicle and therefore not subject to these state traffic laws. He claims that the
municipal court has no jurisdiction to prosecute him.
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Plaintiff also indicates that he is challenging Willoughby Municipal Court Case Nos. 23TRD
05547, 23CRB02689, 23TRD02196, and 23TRD05715. Plaintiff filed a previous action in this
court challenging Case Nos. 23TRD 05547, 23CRB02689. Those cases were consolidated and
assigned to Judge Donald C. Nugent. Case No. 23TRD02196 is the subject of an action assigned
to Judge David A. Ruiz. The facts of this case pertain to Case No. 23TRD05715. This Court
will only address the charges pending in Case No. 23TRD05715.
I.
BACKGROUND
Plaintiff’s Complaint is difficult to decipher. It appears that he was stopped by Kirtland
Police on November 2, 2023 for failing to display a valid license plate on his personal vehicle.
He was charged on November 6, 2023 in the Willoughby Municipal Court with driving with
fictitious plates in Case No. 23TRD05715. The Municipal Court docket indicates he filed
various motions to dismiss, a claim of sham legal process, a statement of misuse of commercial
identification, and an “Affidavit of White Flag of Truce, Motor Vehicle Codes as Commercial
Jurisdiction.” These Motions did not convince the Municipal Court to dismiss the charge. The
case was set for trial in October 2024, but Plaintiff failed or refused to appear in court. The
criminal case is still pending.
Plaintiff filed this action in federal court to challenge the state’s on-going prosecution.
He subscribes to the belief that only commercial use of a vehicle can require a license, license
plate, and vehicle registration. He contends that there are no license and registration
requirements for private vehicles used for private purposes. He asserts that the Municipal Court
has not agreed with his assertions and his prosecution violates his rights under the Fourth, Fifth,
Sixth, and Seventh Amendments.
II.
ANALYSIS
The comity-based abstention doctrine developed in Younger v. Harris prevents federal
courts from interfering in pending state-court criminal proceedings, even if there is an allegation
of a constitutional violation, unless there is an extraordinary circumstance “where the danger of
irreparable loss is both great and immediate.” 401 U.S. 37, 45 (1971). The Younger abstention
doctrine reflects strong federal policy against federal interference with state judicial proceedings
and promotes the presumption that state courts are equally competent at safeguarding federal
constitutional rights. Id. Younger abstention is not a question of jurisdiction but is rather based
on “strong policies counseling against the exercise of such jurisdiction.” Ohio Civil Rights
Comm’n v. Dayton Christian Sch., Inc., 477 U.S. 619, 626 (1986). The Younger abstention
doctrine may be raised sua sponte by a federal court. O’Neill v. Coughlan, 511 F.3d 638, 642
(6th Cir. 2008).
When a person is the target of an ongoing state action involving important state matters,
he or she cannot interfere with the pending state action by maintaining a parallel federal action
involving claims that could have been raised in the state case. Watts v. Burkhart, 854 F.2d 839,
844–48 (6th Cir. 1988). If the state defendant files such a case, Younger abstention requires the
federal court to defer to the state proceeding. Id.; see also Pennzoil Co. v. Texaco, Inc., 481 U.S.
1, 15 (1987). Based on these principles, abstention is appropriate if: (1) state proceedings are ongoing; (2) the state proceedings implicate important state interests; and (3) the state proceedings
afford an adequate opportunity to raise federal questions. Middlesex Cnty. Ethics Comm. v.
Garden State Bar Ass’n, 457 U.S. 423, 432 (1982). Abstention is mandated whether the state
court proceeding is criminal, quasi-criminal, or civil in nature if federal court intervention
“unduly interferes with the legitimate activities of the state.” Younger, 401 U.S. at 44.
All three factors supporting abstention are present. The case in the Willoughby
Municipal Court, No. 23TRD05715, is still pending and this Court acknowledges that state court
criminal matters are of paramount state interest. See Younger, 401 U.S. at 44–45. Plaintiff
claims that his traffic stop, and detention, constitute an unreasonable search and seizure in
violation of the Fourth Amendment. He also challenges the jurisdiction of the state court to
prosecute him. These claims go to the heart of the pending state court criminal case.
The third requirement of Younger requires Plaintiff to have an opportunity to assert his
federal challenges in the state court proceeding. The pertinent inquiry is whether the state
proceedings afford an adequate opportunity to raise the federal claims, not whether Plaintiff was
successful in obtaining the relief he requested. Moore v. Sims, 442 U.S. 415, 430 (1979). The
burden rests with Plaintiff to demonstrate state procedural law bars presentation of his claims.
Pennzoil Co., 481 U.S. at 14. Although Plaintiff has filed motions during the criminal
proceedings, and the Municipal Court has not been persuaded by his arguments, and he still can
raise those arguments at trial or on appeal if he is convicted. He, however, refused to appear at
trial. The requirements of Younger are met. This Court will not interfere in a pending state court
criminal case by deciding issues that are central to that state case.
Therefore, the Court finds that the Younger doctrine applies and requires federal
abstention in this case. Because Plaintiff’s claims seek only monetary damages, the Court must
stay this case until his state-court case (including any appeals) have concluded.
III.
CONCLUSION
Accordingly, all proceedings in this case are stayed pending the conclusion of Kirtland v.
Harris, No. 23TRD05715 (Willoughby Mun. Ct. filed Nov. 6, 2023), including all appeals. This
case is administratively closed, subject to reopening upon a written motion to reopen filed by
Plaintiff demonstrating the Municipal Court case listed above and all appeals in that case have
been resolved or concluded. No claims or defenses are waived as a result of the stay. All
pending motions are denied without prejudice subject to refiling in the event the case is
reopened. Because this case is stayed, from this point forward, the only motion the Court will
entertain is a motion to reopen that demonstrates that the state court criminal charges in Case No.
23TRD05715 have been resolved with either dismissal of the charges or a conviction. Until a
motion to reopen is granted, no other filings will be considered by the Court.
IT IS SO ORDERED.
Date: January 28, 2025
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BRIDGET MEEHAN BRENNAN
UNITED STATES DISTRICT JUDGE
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