STEADMAN v. FORD

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UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF FLORIDA
PANAMA CITY DIVISION
JAMIE ALAN STEADMAN,
Petitioner,
vs. 	Case No.: 5:26-cv-147-MW-ZCB
SHERIFF TOMMY FORD,
Respondent.
___________________________________/
REPORT AND RECOMMENDATION
Petitioner has filed a pro se habeas petition under 28 U.S.C. § 2241.
(Doc. 1). 	The petition challenges Petitioner’s ongoing state criminal
proceedings. 	For the reasons below, this case should be dismissed
because abstention is warranted under Younger v. Harris, 401 U.S. 37
(1971).
I. 	Background
Petitioner currently faces charges in state court. 	See State v.
Steadman, Case No. 19001533CFMA (Bay Cnty. Cir. Ct.).1 On August 4,
2020, the state court found Petitioner incompetent to proceed in a
separate 	case 	and 	granted 	Petitioner 	pretrial 	release 	in 	Case 	No.
1 See Fed. R. Evid. 201(b)-(c); Nute v. White, 152 F.4th 1311, 1316 (11th
Cir. 2025) (taking judicial notice of online state court records).
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19001533CFMA.2 	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).
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 a bench warrant. 	Petitioner says that 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 	is 	being 	improperly 	restrained 	based 	on
untimely charges, indefinite prosecution, denial of access to courts, and
speedy trial violations. (Id. at 5-7). Petitioner seeks the dismissal of all
criminal charges. (Id. at 7-8).
2 Petitioner was found incompetent to proceed in the felony case on
August 26, 2020. 	See Steadman, Doc. 140, Case No. 19001533CFMA
(Bay Cnty. Cir. Ct.).
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The Court initially reviewed the habeas petition and determined
that it appeared Younger abstention applied.3 	(Doc. 7). For this reason,
the Court ordered Petitioner to show cause why his habeas petition
should not be dismissed. (Id.). The deadline to respond to the show cause
order has passed, and Petitioner has not responded.
II. 	Discussion
Dismissal 	of 	the 	habeas 	petition 	is 	warranted 	because 	of 	the
abstention doctrine announced in Younger v. Harris, 401 U.S. 37 (1971).
Under Younger, “a federal court should not interfere with ongoing state
criminal proceedings where the state court conviction and/or sentence is
3 See Rule 4, Rules Governing § 2254 Cases (requiring prompt judicial
review of a habeas petition and explaining that “[i]f it plainly appears
from the petition and any attached exhibits that the petitioner is not
entitled to relief in the district court, the judge must dismiss the petition
and direct the clerk to notify the petitioner”); see also Rule 1(b), Rules
Governing § 2254 Cases (stating that a district court “may apply any or
all of these rules to a habeas corpus petition” that has not been filed
under § 2254); Jackson v. Georgia, 273 F. App’x 812, 813-14 (11th Cir.
2008) (affirming sua sponte dismissal on Younger abstention grounds in
a 	case 	that 	attempted 	to 	challenge 	an 	ongoing 	state 	criminal
prosecution); McGowan v. Dir. of Miami-Dade Dep’t of Corr., No. 22-
13720, 2023 WL 7321634, at *1 (11th Cir. June 7, 2023) (finding that
“reasonable jurists would not debate the district court’s [sua sponte]
dismissal” of the habeas petition because “the district court correctly
determined that [the petitioner’s] claims were subject to the Younger
abstention doctrine” (cleaned up)).
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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. 	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.” 	Id.
Here, the requirements of Younger abstention are met. First, there
are state criminal proceedings against Petitioner pending in state court.
See State v. Steadman, Case No. 19001533CFMA (Bay Cnty. Cir. Ct.).
Second, a state criminal prosecution involves important state interests.
See Boyd v. Georgia, 512 F. App’x 915, 918 (11th Cir. 2013) (explaining
that the state has an important interest in prosecuting criminal offenses).
Third, to the extent Petitioner asserts he has been unable to
vindicate his constitutional rights because the state court has been
dismissing his pro se filings and not adjudicating anything (Doc. 1 at 4-5,
7), he has not shown that he has been procedurally prevented from
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raising his federal claims in the state courts. 	Since being declared
incompetent to proceed, Petitioner has submitted numerous pro se filings
in the state court, including a pro se habeas petition. 	See Steadman,
Docs. 180 to 183, 185 to 188, Case No. 19001533CFMA (Bay Cnty. Cir.
Ct.). Thus, 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); see
Johnson, 32 F.4th at 1101 (“For abstention purposes, whether a claim
would likely be successful on the merits in the state court is not what
matters. 	Instead, what matters is whether the plaintiff is procedurally
prevented from raising his constitutional claims in the state courts[.]”
(cleaned up)). Moreover, Petitioner is represented by counsel in the state
criminal proceedings. There is no reason to believe that the Florida state
court where the criminal action is pending will not afford Petitioner an
adequate opportunity to raise the issues presented in his § 2241 petition.4
4 Petitioner’s dissatisfaction with his state-appointed attorney in the
criminal case (Doc. 1-1 at 4) is also insufficient to overcome Younger. See
Prouty v. Warden, Lee Cnty. Jail, 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
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Because the three requirements of Younger abstention are met,
“abstention is warranted unless [Petitioner] can show that one of the
exceptions applies.” 	Leonard, 61 F.4th at 911. 	None do. 	Looking first
to the bad-faith exception, “bad faith in this context generally means that
a prosecution has been brought without a reasonable expectation of
obtaining a valid conviction.” 	Id. (cleaned up). 	Here, to the extent
Petitioner has even invoked the bad-faith exception, he has not shown
that the state prosecution was brought with no “reasonable expectation”
of securing a conviction. 	Thus, he has not satisfied Younger’s bad-faith
exception. 	See Narciso v. Walker, 811 F. App’x 600, 602-03 (11th Cir.
2020) (noting that “unsupported” and “conclusory allegations do not rise
to the level necessary to justify an exception to Younger abstention”
(cleaned up and collecting cases)).
The 	Court 	will 	now 	turn 	to 	the 	second 	exception. 	To 	show
irreparable injury in the context of an ongoing state criminal prosecution,
Petitioner must demonstrate that “the danger of irreparable loss is both
great and immediate.” Younger, 401 U.S. at 45. Petitioner has not made
such a showing here. 	The mere fact that Petitioner faces arrest and
application of a recognized exception to the Younger doctrine.”).
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prosecution (Doc. 1 at 7) is not an injury sufficient to circumvent Younger
abstention. 	See Hughes v. Att’y Gen. of Fla., 377 F.3d 1258, 1263 & 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)). 	Thus, there is no reason for the Court to believe that
abstaining will result in Petitioner suffering irreparable injury.
As for the third exception, Petitioner has failed to show that the
Florida state courts are an inadequate forum to raise his constitutional
challenges. “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.” Leonard, 61 F.4th at 908 (cleaned up).
Put another way, “what matters is whether the plaintiff is procedurally
prevented from raising his constitutional claims in the state courts[.]” Id.
at 908 (cleaned up). 	Petitioner has pointed to nothing in Florida state
law or procedure that would prohibit him from raising in state court the
same issues he has raised in his § 2241 petition. 	Indeed, Florida state
courts regularly entertain and adjudicate such issues. 	And nothing
suggests Petitioner cannot appeal to the Florida appellate courts if the
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state trial courts deny relief. See Lewis v. Broward Cnty. Sheriff Off., No.
20-14603, 2021 WL 5217718, at *2 (11th Cir. Nov. 9, 2021) (“Lewis failed
to meet his burden to show that he lacked an adequate, alternative state
forum to raise his constitutional claims because the record demonstrated
his state proceedings were ongoing and he had been able to raise other
claims to the state court, including his petitions for mandamus and
motion to remove his appointed counsel, but failed to challenge the state
court’s bond decision or file a state habeas petition.”).
For 	these 	reasons, 	Younger 	abstention 	serves 	as 	a 	basis 	for
dismissal of this case. 	See Jackson v. Georgia, 273 F. App’x 812, 813-14
(11th Cir. 2008) (affirming sua sponte dismissal on Younger abstention
grounds in a case that attempted to challenge an ongoing state criminal
prosecution); see also Rossi v. State of Florida No. 4:26cv121, 2026 WL
1954377, at *1-4 (N.D. Fla. May 8, 2026) (dismissing pretrial detainee’s
§ 2241 petition sua sponte on Younger abstention grounds), adopted, 2026
WL 1952759 (N.D. Fla. July 6, 2026).
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III. 	Conclusion
Because 	Petitioner’s 	habeas 	petition 	is 	subject 	to 	Younger
abstention, this matter should be dismissed without prejudice.
IV. 	Certificate of Appealability
When a § 2241 “petitioner’s detention arises out of process issued
by a State court, he must obtain a certificate of appealability to appeal.”
Georgia v. Shafer, 119 F.4th 1317, 1321 (11th Cir. 2024) (cleaned up). “To
obtain a certificate, the petitioner must make ‘a substantial showing of
the denial of a constitutional right.’” Id. (quoting 28 U.S.C. § 2253(c)(2)).
“At the COA stage, the only question is whether the applicant has shown
that jurists of reason could disagree with the district court’s resolution of
his 	constitutional 	claims 	or 	that 	jurists 	could 	conclude 	the 	issues
presented are adequate to deserve encouragement to proceed further.”
Buck v. Davis, 580 U.S. 100, 115 (2017) (cleaned up).
Here, Petitioner cannot make the requisite showing. Therefore, the
undersigned recommends that the final order in this case deny Petitioner
a certificate of appealability. If Petitioner objects to this recommendation,
then he may present argument on the issue by bringing it to the district
judge’s attention in his objections.
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Accordingly, it is respectfully RECOMMENDED that:
1. 	The habeas petition under 28 U.S.C. § 2241 	(Doc. 1) be
DISMISSED without prejudice based on Younger abstention.
2. 	A certificate of appealability be DENIED.
3. 	The Clerk of Court be instructed to close this case.
At Pensacola, Florida this 13th day of August 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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