STEADMAN v. FORD

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UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF FLORIDA
PANAMA CITY DIVISION
JAMIE ALAN STEADMAN,
Petitioner,
v. 	Case No.: 5:26-cv-147-MW-ZCB
SHERIFF TOMMY FORD,
Respondent.
____________________________________/
REPORT AND RECOMMENDATION
Petitioner is proceeding pro se in this habeas action under 28 U.S.C.
§ 2241. (Doc. 1). Before the Court is Petitioner’s “Motion to Stay Bench
Warrant” (Doc. 2), which the Court construes as a motion for temporary
restraining order. For the reasons below, the motion should be denied.
I. Background
Petitioner currently faces charges in state court.1 	On August 4,
2020, 	the 	state 	court 	found 	Petitioner 	incompetent 	to 	proceed 	and
granted 	Petitioner 	pretrial 	release. 	Petitioner 	was 	ordered 	to
“community-based competency restoration” and released to reside in
Virginia. 	Petitioner 	claims 	competency 	restoration 	has 	not 	been
provided. (Doc. 1 at 1-3).
1 See State v. Steadman, No. 19001533CFMA (Bay Cnty. Cir. Ct.).
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On August 4, 2021, Petitioner notified his state-appointed counsel
that he was moving to South Carolina. Petitioner alleges that his counsel
never informed the state court about the move and never told Petitioner
about any hearings in the state court. After Petitioner’s counsel allegedly
stopped communicating with him, Petitioner missed a status hearing
held by the state court on February 25, 2022. As a result, the state court
issued the bench warrant Petitioner now seeks to stay. Petitioner claims
his counsel refuses to file motions on his behalf in state court and that
the state court has dismissed his pro se filings. (Id. at 3-4).
Petitioner claims he faces the irreparable harm of being arrested if
the warrant is not stayed. Petitioner argues he is likely to succeed on the
merits because Florida law requires dismissal of criminal charges after
five years of incompetency. Petitioner also claims the balance of equities
and public interest favor a stay. (Doc. 2 at 3-4; Doc. 1 at 5).
II. Discussion
To receive a temporary restraining order, a movant must show that:
(1) there is a substantial likelihood of success on the merits; (2) an
irreparable injury will be suffered if the restraining order is not granted;
(3) 	the 	threatened 	injury 	to 	the 	movant 	outweighs 	any 	injury 	the
proposed restraining order might cause the opposing party; and (4) the
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restraining order would not be adverse to the public interest.2 	In re
Gateway Radiology Consultants, P.A., 983 F.3d 1239, 1254 (11th Cir.
2020). Petitioner “bears the burden of persuasion to clearly establish all
four of these prerequisites.” 	Wreal, LLC v. Amazon.com, Inc., 840 F.3d
1244, 1247 (11th Cir. 2016) (cleaned up). And “failure to meet even one”
prerequisite justifies denial. 	Id. at 1248.
A. Petitioner has not shown a substantial likelihood of success
on the merits.
First, Petitioner has not shown a substantial likelihood of success
on the merits. 	Petitioner argues he is likely to succeed on the merits
because Fla. Stat. § 916.145 requires dismissal of his felony case. 	(Doc.
2 at 3). The Court disagrees for several reasons.
1. Habeas relief is not available for errors of state law
Petitioner’s argument that state law requires dismissal of his
pending state case has no bearing on whether he will be successful in
obtaining federal habeas relief. 	Petitioner “is only entitled to federal
habeas relief under § 2241 if he can demonstrate that he is in custody in
violation of the Constitution or laws or treaties of the United States.”
2 The “four criteria for obtaining a preliminary injunction are identical to
those for issuance of a temporary restraining order[.]” Windsor v. United
States, 379 F. App’x 912, 916-17 (11th Cir. 2010).
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Sanders v. Granthum, No. CV 25-107, 2025 WL 4654894, at *1 (S.D. Ala.
Mar. 18, 2025) (cleaned up). Even if Petitioner is correct that Florida law
mandates dismissal of his state case, that is not a ground for federal
habeas relief. See Estelle v. McGuire, 502 U.S. 62, 67 (1991) (stating that
“federal habeas corpus relief does not lie for errors of state law”); see also
Broom v. Fla. Parole Comm’n, No. 2:03-cv-435, 2008 WL 186533, at *9
(M.D. 	Fla. 	Jan. 	18, 	2008) (“To the 	extent 	that 	the 	Petition 	claims
violations of state statutes or the Florida Constitution . . . , such claims
are not cognizable under § 2241 or § 2254 because federal habeas relief
is not available for errors of state law.”). Thus, Petitioner has not shown
a substantial likelihood that he will succeed on his 28 U.S.C. § 2241
petition based on a violation of Florida law.3
2. Younger abstention
Petitioner also has not shown a likelihood of success on the merits
because it appears Younger abstention poses an obstacle to Petitioner
3 The Court need not address the federal claims in the § 2241 petition
(Doc. 1 at 5-7) because Petitioner’s TRO motion references only the
alleged violation of Florida law. 	(Doc. 2 at 3). 	See Brown v. Coffin, 766
F. App’x 929, 931 (11th Cir. 2019) (“Although we read briefs filed by pro
se litigants liberally, issues not briefed . . . by a pro se litigant are deemed
abandoned.”).
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obtaining habeas relief in this case.4 	Under Younger, “a federal court
should not interfere with ongoing state criminal proceedings where the
state court conviction and/or sentence is not yet final.” 	Johnson v.
Florida, 32 F.4th 1092, 1099 (11th Cir. 2022). 	“Younger abstention is
required when: (1) state proceedings, judicial in nature, are pending; (2)
the state proceedings involve important state interests; and (3) the state
proceedings 	afford 	adequate 	opportunity 	to 	raise 	the 	constitutional
issue.” 	Id.
Here, as to the first two elements, it is apparent that Petitioner’s
state 	case 	is 	ongoing 	and 	that 	state 	criminal 	prosecutions 	involve
important state interests. See id. As to the third element, Petitioner has
not met his burden of “show[ing] that the state forum is not adequate to
adjudicate [his] federal defenses.” 	Leonard v. Alabama State Bd. of
Pharmacy, 61 F.4th 902, 908 (11th Cir. 2023). Petitioner’s petition claims
the state court’s dismissal of his 	pro se 	filings deprived him of an
adequate opportunity to raise any constitutional issues. 	(Doc. 1 at 4-5,
7). But Petitioner’s filings were dismissed because he has been declared
incompetent and is represented by counsel. 	See No. 19001533CFMA
4 See Younger v. Harris, 401 U.S. 37 (1971).
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(Bay Cnty. Cir. Ct.) (docket entry dated May 19, 2026).5 The filings were
not dismissed because Petitioner’s claims were procedurally barred by
Florida law. See id. Petitioner has also objected to the dismissal and has
filed a pro se habeas petition in the state court—thereby showing that
Petitioner is currently raising his constitutional arguments in state
court. 	See id. (docket entries dated May 22, 2026, and June 5, 2026); see
also Leonard, 61 F.4th at 908 (“Adequacy in this context is not about the
quality of the state proceedings, but rather about whether the challenge
can be raised in the pending state proceedings at all.” (cleaned up)).
A final point on the third 	Younger 	element: Petitioner’s state-
appointed counsel’s refusal to file motions that Petitioner would like her
to file (Doc. 1-1 at 4) does not mean that Florida law procedurally bars
Petitioner from raising his constitutional arguments in the state court.6
Because Younger abstention appears warranted, the Court must
5 See Fed. R. Evid. 201(b)-(c); see also Nute v. White, 152 F.4th 1311, 1316
(11th Cir. 2025) (taking judicial notice of online state court records).
6 See Prouty v. Warden, Lee Cnty. Jail, No. 2:24cv1101, 2024 WL 5293775,
at *1 (M.D. Fla. Dec. 4, 2024) (“Prouty argues the Court should overlook
the abstention principle because he is not satisfied with his state-
appointed attorney or the responsiveness of the state court. 	The Court
does not find these circumstances sufficient to overcome Younger. 	Nor
do they warrant application of a recognized exception to the Younger
doctrine.”).
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determine if any exception applies. There are three narrow exceptions to
Younger abstention: “(1) there is evidence of state proceedings motivated
by bad faith; (2) irreparable injury would occur; or (3) there is no
adequate alternative state forum where the constitutional issues can be
raised.” 	Johnson, 32 F.4th at 1099.
Petitioner 	argues 	that 	he 	faces 	irreparable 	injury 	and 	that
extraordinary 	circumstances 	exist 	because 	the 	state 	court 	is 	not
adjudicating 	anything. 	(Doc. 	1 	at 	7). 	The 	Court 	construes 	these
arguments as invoking the Younger exceptions for irreparable injury and
no adequate alternative state forum. 	But neither of those exceptions
appears to apply here.
As to irreparable injury, the mere fact that Petitioner faces arrest
and 	prosecution 	is 	not 	an 	injury 	sufficient 	to 	circumvent 	Younger
abstention. See Hughes v. Att’y Gen. of Fla., 377 F.3d 1258, 1263 and n.7
(11th Cir. 2004) (noting that “the cost, anxiety, and inconvenience of
having to defend against a single criminal prosecution alone do not
constitute irreparable injury in the special legal sense of that term”
(cleaned up)).
Petitioner 	has 	also 	failed 	to 	show 	that 	there 	is 	no 	adequate
alternative state forum to raise his constitutional claims. As mentioned,
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Petitioner 	has 	a 	pending 	state 	habeas 	petition. 	See 	No.
19001533CFMA (Bay Cnty. Cir. Ct.) (docket entry dated June 5, 2026).
And nothing suggests Petitioner cannot appeal to the Florida appellate
courts if the state trial courts deny relief on the state habeas petition.
See Dixon v. Polisknowski, No. 4:25cv268, 2025 WL 3646607, at *2-3
(N.D. Fla. July 25, 2025) (abstaining under Younger where petitioner
appealed a state court’s competency decision and “filed a habeas petition
which was denied by the circuit court”), adopted, 2025 WL 3645865 (N.D.
Fla. Dec. 15, 2025).7
3. Petitioner’s claims appear unexhausted
Lastly, Petitioner has not shown a substantial likelihood of success
on the merits because his claims appear unexhausted. 	A “district court
may not grant a § 2241 petition unless the petitioner has exhausted all
available state remedies.” Johnson, 32 F.4th at 1095-96 (cleaned up). In
§ 2241 cases, “[e]xhaustion has two essential requirements . . . .” 	Id. at
1096. First, “a federal claim must be fairly presented to the state courts.”
7 Although not raised in the motion, it bears mentioning that Petitioner’s
speedy 	trial 	claims 	do 	not 	appear 	to 	constitute 	extraordinary
circumstances sufficient to overcome Younger. 	See Johnson, 32 F.4th at
1099 (collecting cases holding that federal courts should abstain from
considering 	speedy 	trial 	claims 	at 	the 	pre-trial 	stage 	barring 	an
independent showing of bad faith or other extraordinary circumstances).
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Id. Second, a petitioner “must take his claim to the state’s highest court,
either on direct appeal or on collateral review.” 	Id. (cleaned up).
Petitioner claims exhaustion should be excused because the state
court dismissed his pro se filings and his attorney will not file anything
on his behalf. 	(Doc. 1 at 4-5). 	The Court disagrees. 	Nothing before the
Court suggests that Petitioner has taken his claims to Florida’s appellate
courts or that he has been precluded by Florida law from doing so. 	As
such, 	it 	appears that 	Petitioner has 	not 	exhausted 	his 	state 	court
remedies. 	See Corpus v. Sec’y, Dep’t of Child. & Fam. Servs., No.
2:24cv812, 2024 WL 4443116, at *1 (M.D. Fla. Sept. 25, 2024) (“Corpus
sought collateral relief in state court by filing a Petition for Writ of
Habeas Corpus . . . . 	[The state court] denied the petition on August 5,
2024. 	Corpus did not appeal. 	Because Corpus has not exhausted the
means of relief available to him under Florida law, his federal habeas
petition is premature.”).
B. Petitioner has not shown that staying the bench warrant
will not be adverse to the public interest.
Although the failure to show a substantial likelihood of success on
the merits is sufficient to deny Petitioner’s motion, the motion is also due
to be denied because Petitioner has not shown that the public interest
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favors granting his motion. 	Petitioner argues the public has no interest
in incarcerating him on charges that must be dismissed under state law.
Petitioner also argues the public interest is served by allowing this Court
to resolve constitutional questions before harm occurs. 	(Doc. 2 at 3-4).
The Court disagrees.
As to Petitioner’s first argument, “equity must be sensitive to the
State’s strong interest in enforcing its criminal judgments without undue
interference from the federal courts.” 	Hill v. McDonough, 547 U.S. 573,
584 (2006). 	Given the State’s strong interest in prosecuting criminal
cases, Petitioner has not shown that the public interest weighs in favor
of granting his motion and staying the bench warrant. 	See Robinson v.
Kaufman, No. 1:11cv657, 2011 WL 7431075, at *1 (M.D. Ala. Dec. 13,
2011) (declining to enjoin state criminal proceedings because, inter alia,
the 	public 	interest 	favored 	not 	interfering 	with 	the 	state 	criminal
process), adopted, 2012 WL 651646 (M.D. Ala. Feb. 29, 2012); Georgia v.
Clark, No. 1:23cv3721, 2023 WL 11796094, at *5 (N.D. Ga. Nov. 9, 2023)
(declining to stay remand of a criminal case removed under 28 U.S.C. §
1455 	because 	“the 	public 	interest 	in 	this 	case 	favors 	comity 	and
federalism, which would not be served by issuing an emergency stay of
the remand order”).
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As to the second argument, Petitioner has not shown that the state
court is not competent to hear Petitioner’s constitutional challenges.
“Article VI of the United States Constitution declares that the Judges in
every State shall be bound by the Federal Constitution, laws and treaties.
Thus, the state courts share equivalently with the federal courts the
responsibility of protecting constitutional guarantees. Absent facts to the
contrary it must be presumed that this obligation will be fulfilled.”
Williams v. Rubiera, 539 F.2d 470, 474 (5th Cir. 1976) (cleaned up).8 	In
other words, “principles of equity and comity” underlie the rule that
“absent extraordinary circumstances federal courts should not enjoin
pending state criminal prosecutions.” 	Hughes, 377 F.3d at 1262-63.
Because the Florida courts are capable of hearing Petitioner’s
constitutional claims in the first instance, Petitioner has not shown that
the public interest weighs in favor of a federal court interfering with the
state criminal proceedings. 	See Williams, 539 F.2d at 474 (“This Court
will not enter into valid state proceedings upon the presage of plaintiff
that her claim will not be recognized in Florida courts. 	The concern of
8 See Joyner v. City of Atlanta, 170 F.4th 1320, 1342 n.5 (11th Cir. 2026)
(“Decisions by the former Fifth Circuit handed down before October 1,
1981, are binding [in the Eleventh Circuit].”).
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comity is not whether a state litigant would win or lose, but whether the
claim to constitutional right would be fairly considered.”); Johnson, 32
F.4th at 1101 (“[T]he state judicial system may retain undisturbed
jurisdiction 	despite 	possibly 	erroneous 	trial 	court 	disposition 	of
constitutional issues. Mere errors or mistakes by the state trial court are
not special circumstances which justify federal intervention.” (cleaned
up)).
C. Petitioner has not shown that the threatened injury to him
outweighs any potential injury to the opposing party.
Additionally, Petitioner has not shown that the threatened injury
to him outweighs the potential injury to the opposing party. As discussed
above, the State of Florida has a strong interest in prosecuting its
criminal cases without federal interference. 	And Petitioner has not
shown that the potential threatened injury he would face outweighs the
potential injury to the State from federal court interference with the
State’s prosecution. 	See Clark, 2023 WL 11796094, at *4 (declining to
stay remand of criminal case) (“[T]he State has a strong interest in its
criminal prosecutions being free from federal interference . . . . Thus, the
strong federalism interests at stake here counsel that the Court weigh
the potential for the State to be prejudiced against Clark’s stay request.”).
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III. 	Conclusion
For the reasons above, it is respectfully RECOMMENDED that
Petitioner’s “Motion to Stay Bench Warrant” (Doc. 2) be DENIED.
At Pensacola, Florida this 24th day of June 2026.
/s/ Zachary C. Bolitho
Zachary C. Bolitho
United States Magistrate Judge
Notice to the Parties
Objections to these proposed findings and recommendations must
be 	filed 	within 	fourteen 	days 	of 	the 	date 	of 	the 	Report 	and
Recommendation. 	Any 	different 	deadline 	that 	may 	appear 	on 	the
electronic docket is for the Court’s internal use only and does not control.
An objecting party must serve a copy of the objections on all other parties.
A 	party 	who 	fails 	to 	object 	to 	the 	magistrate 	judge’s 	findings 	or
recommendations contained in a report and recommendation waives the
right 	to 	challenge 	on 	appeal 	the 	district 	court’s 	order 	based 	on
unobjected-to factual and legal conclusions. 	See 11th Cir. Rule 3-1; 28
U.S.C. § 636.
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