TAHAI v. STANFILL et al

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UNITED STATES DISTRICT COURT
DISTRICT OF MAINE
JUSTIN TAHAI, 	)
)
Plaintiff 	)
)
v. 	) 	No. 2:26-cv-00057-LEW
)
VALERIE STANFILL et al., 	)
)
Defendants 	)
RECOMMENDED DECISION AFTER PRELIMINARY REVIEW
Because I granted Justin Tahai’s application to proceed in forma pauperis, see
Order (ECF No. 5), his complaint (ECF No. 1) is now before me for preliminary review
in 	accordance 	with 	28 U.S.C. 	§ 1915(e)(2)(B). 	For 	the 	reasons 	that 	follow,
I recommend that the Court dismiss the Plaintiff’s complaint.
I. Legal Standard
The federal in forma pauperis statute, 28 U.S.C. § 1915, is designed to ensure
meaningful access to federal courts for persons unable to pay the costs of bringing an
action. 	See Neitzke v. Williams, 490 U.S. 319, 324 (1989). 	When a party proceeds
in forma pauperis, however, a court must “dismiss the case at any time if” it
determines that the action “is frivolous or malicious[,] . . . fails to state a claim on
which relief may be granted,” or “seeks monetary relief against a defendant who is
immune from such relief.” 28 U.S.C. § 1915(e)(2)(B). Dismissals under section 1915
are often made on the court’s own initiative “prior to the issuance of process, so as to
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spare prospective defendants the inconvenience and expense of answering” meritless
complaints. Neitzke, 490 U.S. at 324.
When considering whether a complaint states a claim for which relief may be
granted, the court must accept the truth of all well-pleaded facts and give the plaintiff
the benefit of all reasonable inferences. 	See Ocasio-Hernández v. Fortuño-Burset,
640 F.3d 1, 12 (1st Cir. 2011). 	A complaint fails to state a claim when it does not
plead 	“enough 	facts 	to 	state 	a 	claim 	to 	relief 	that 	is 	plausible 	on 	its 	face.”
Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). 	An unrepresented plaintiff’s
complaint must be read liberally in this regard, see Donovan v. Maine, 276 F.3d 87,
94 (1st Cir. 2002), but must still contain “the crucial detail of who, what, when,
where, and how” in order to provide fair notice of what the claims are and the grounds
upon which they rest, Byrne v. Maryland, No. 1:20-cv-00036-GZS, 2020 WL 1317731,
at *5 (D. Me. Mar. 20, 2020) (rec. dec.), aff’d, 2020 WL 2202441 (D. Me. May 6, 2020).
II. Allegations
In his complaint, Tahai alleges that he has been denied custody of his child for
417 days during the pendency of a state court case. Complaint (ECF No. 1) ¶¶ 8-10.
He alleges that the delay in resolving that case has deprived him of his fundamental
parental right to direct the care and upbringing of his child. Id. To remedy the delay,
Tahai asks this Court to enter a declaratory judgment stating that the delay has
violated his due process right guaranteed by the Fourteenth Amendment and to issue
preliminary 	and 	permanent 	injunctions 	forcing 	the 	State 	Court 	to 	implement
procedural safeguards to ensure the timely resolution of his case and others like it.
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Id. at 2. Tahai’s complaint and a subsequent emergency motion show that he has not
exhausted the state trial and appellate process. See id.; Motion (ECF No. 9).
III. Discussion
Under Younger v. Harris, 401 U.S. 37 (1971), federal courts generally abstain
from intervening in state court proceedings, including those involving custody of a
minor child. 	See Moore v. Sims, 442 U.S. 415, 423 (1979) (“The Younger doctrine,
which counsels federal-court abstention when there is a pending state proceeding,
reflects a strong policy against federal intervention in state judicial processes in the
absence 	of 	great 	and 	immediate 	irreparable 	injury 	to 	the 	federal 	plaintiff.”);
Malachowski v. City of Keene, 787 F.2d 704, 708 (1st Cir. 1986) (“[W]e find that the
district court’s abstention from asserting jurisdiction over appellants’ injunctive
claims was fully justified.”). 	“Abstention is appropriate when the requested relief
would interfere (1) with an ongoing state judicial proceeding; (2) that implicates an
important state interest; and (3) that provides an adequate opportunity for the
federal plaintiff to advance his federal constitutional challenge.” 	Rossi v. Gemma,
489 F.3d 26, 34-35 (1st Cir. 2007).
Each element of the Younger abstention analysis is satisfied here. First, there
is an ongoing state proceeding as demonstrated in both the complaint and the
subsequent “Emergency MOTION to Prevent Continuing Denial of Meaningful
Access to the Courts.” Motion at 1. Second, Maine has a “compelling state interest”
in protecting children, and “[f]amily relations are a traditional area of state concern.”
Moore, 442 U.S. at 435. Finally, there is an appellate process—generally following a
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final judgment from the trial court—that safeguards the Plaintiff’s federal rights
relevant to the case currently before the Court. 	See, e.g., 19-A M.R.S.A. § 1774
(providing 	for 	appeals 	from 	final 	orders 	under 	the 	Uniform 	Child 	Custody
Jurisdiction and Enforcement Act); id. § 104 (providing for appeals from final orders
involving 	Title 	19-A 	of 	the 	Maine 	Statutes 	governing 	Domestic 	Relations);
Robb v. Connolly, 111 U.S. 624, 637 (1884) (recognizing the concurrent jurisdiction of
state courts to hear issues “arising under the constitution or laws of the United
States, or involving rights dependent upon such constitution or laws”).1
Applying the principles of comity and federalism, federal courts should not
intervene to expedite state court proceedings.2 	See SKS & Associates, Inc. v. Dart,
619 F.3d 674, 682 (7th Cir. 2010) (declining to “supervise” state court proceedings).
Accordingly, I recommend that the Court abstain from hearing this case and dismiss
the complaint, as it seeks only declaratory and injunctive relief. 	Cf. Nass v. Maine
Bd. of Licensure in Med., 1:23-cv-00321-LEW, 2024 WL 3520931, at *9 (D. Me. July
24, 	2024) 	(“A 	court 	that 	abstains 	from 	exercising 	jurisdiction 	under 	Younger
1 Additionally, “[t]he burden is on the federal plaintiff to show that state procedural law bars
presentation of his claims.” 	17B Charles Alan Wright & Arthur R. Miller, Federal Practice and
Procedure § 4252 (3d ed.). Tahai has not carried that burden here.
2 Tahai filed the “Emergency Motion” in this Court just over two months after submitting his
complaint. Complaint (ECF No. 1); Motion (ECF No. 9). The motion confirms that the State Court
proceeding is ongoing and asks this Court to prevent the State Court from rejecting his evidentiary
filings and to require prompt judicial review. Motion at 3. This Court, however, cannot direct the
State Court in the management of its docket, see Knox v. Bland, 632 F.3d 1290, 1292 (10th Cir. 2011)
(rejecting petition for mandamus and stating the federal court had “no authority to issue such a writ
to direct state courts or their judicial officers in the performance of their duties.” (cleaned up)), and
Younger abstention should apply. See Moore, 442 U.S. at 435 (“Family relations are a traditional area
of state concern . . . [federal courts] are unwilling to conclude that state processes are unequal to the
task of accommodating the various interests and deciding the constitutional questions that may arise
in child-welfare litigation.”).
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ordinarily dismisses the federal action. However, to the extent that the federal action
includes a damages claim, a court ordinarily may only stay the action, rather than
dismiss the action in its entirety.” (cleaned up)); see also Complaint ¶ 1 (“Plaintiff
seeks prospective declaratory and injunctive relief . . . .”).
IV. Conclusion
For 	the 	foregoing 	reasons, 	I 	recommend 	that 	the 	Court 	DISMISS 	the
Plaintiff’s complaint pursuant to 28 U.S.C. § 1915(e)(2)(B) and MOOT any other
pending motions.
NOTICE
A party may file objections to those specified portions of a Magistrate
Judge’s 	report 	or proposed 	findings 	or 	recommended 	decisions 	entered
pursuant to 28 U.S.C. § 636(b)(1)(B) for which de novo review by the District
Court is sought, together with a supporting memorandum, within fourteen
(14) days after being served with a copy thereof. 	A responsive memorandum
shall be filed within fourteen (14) days after the filing of the objection.
Failure to file a timely objection shall constitute a waiver of the right
to de novo review by the District Court and to appeal the District Court’s
order.
Dated: April 15, 2026
/s/ Karen Frink Wolf
United States Magistrate Judge
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