Unreported / Non-Citable
Background
Michael M. Ward, representing himself, sued the City of Redding Police Department and other defendants under 42 U.S.C. § 1983 in the Eastern District of California. His second amended complaint alleges that he was arrested without a warrant and not given a prompt judicial determination of probable cause. It also alleges malicious prosecution and excessive force. He asks the court to dismiss "fraudulent charges of 148 PC 2 X" and to sanction the defendants. These are only his allegations, and the court made no findings on them.
Ward filed his original complaint on March 24, 2025, together with a motion to proceed in forma pauperis and a motion to compel. The court dismissed it with leave to amend because it was unclear whether the underlying state proceedings had ended, and Younger abstention might apply if they had not. His first amended complaint, filed June 18, 2025, was also dismissed with leave to amend. It did not give the court enough information to decide whether Younger or Rooker-Feldman barred the case, and it did not link Defendant Bridgett to the claims. He filed the second amended complaint on September 30, 2025.
The magistrate judge screened that pleading under 28 U.S.C. § 1915A. That statute covers complaints against governmental defendants brought by prisoners, and it also applies when the plaintiff was incarcerated at the time the action was filed.
The Court’s Holding
The court dismissed the second amended complaint with leave to amend. Ward had been given an earlier chance to clarify whether the state proceedings were ongoing, and he did not do so. The court read his request to dismiss the state charges as an admission that the case is still pending. Because he asks the federal court for relief from a pending state proceeding, the court concluded that under Younger v. Harris it cannot grant that relief. The order explains that Younger applies differently to damages claims than to claims for injunctive or declaratory relief, and that dismissal is appropriate for the latter. It did not separately analyze any damages claim, and it did not decide whether the arrest, prosecution, or force allegations have merit.
The court also declined to impose sanctions. It found it unclear what the sanctions would involve or why they were warranted, other than Ward's displeasure with the results of his state court case. It would not sanction parties or non-parties for conduct in the pending state case.
The order is not a final judgment. Ward has 30 days from service to file a third amended complaint. That pleading must be complete in itself, because an amended complaint supersedes earlier ones and claims not realleged are waived. It must state how each defendant was involved and show an affirmative link between each defendant's actions and the claimed deprivation. The court warned that failing to file within the deadline may be grounds for dismissing the action.
Key Takeaways
- Younger abstention directs a federal court not to grant injunctive or declaratory relief that would interfere with a pending state criminal proceeding, and a request to dismiss state charges falls within that rule.
- The court treated the plaintiff's request to dismiss his charges as an admission that the state case is ongoing, even though he never confirmed its status after being asked to.
- Younger applies differently to damages claims, and this order did not decide whether any damages claim could proceed.
- A dismissal with leave to amend gives the plaintiff another chance to plead. It is not a final judgment, and it does not decide the merits of the arrest, force, or prosecution allegations.
- A sanctions request grounded only in dissatisfaction with a state court outcome was declined.
Why It Matters
This unpublished screening order is not binding precedent, but it shows how federal courts handle self-represented plaintiffs who ask them to end ongoing state prosecutions. After two earlier opportunities, the plaintiff still did not say whether the state case had concluded, and the court resolved the ambiguity against him by treating his own request for dismissal as an admission.
For litigants, the order shows why a federal pleading should state plainly where the state case stands and should tie each defendant to specific conduct. It also shows that a third amended complaint must be a standalone document. The order does not foreclose all relief. It leaves open whether a properly pleaded complaint could state claims that Younger does not bar.