4:25-cv-00358•ROYCE v. MCNEIL
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Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION SAMUEL DAVID ROYCE, Petitioner, v. Case No. 4:25-cv-358-TKW-MJF WALT MCNEIL, Respondent. / REPORT AND RECOMMENDATION Petitioner Samuel Royce is a Florida pretrial detainee confined at the Leon County Detention Facility. In his petition pursuant to 28 U.S.C. § 2241, Royce seeks release from pre-trial detention and complains about his conditions of confinement. Doc. 1 at 1, 7. Because the abstention doctrine articulated in Younger v. Harris, 401 U.S. 37 (1971) precludes the District Court from interfering in Florida’s ongoing prosecution of Royce, and because Royce’s claims concerning conditions of confinement can only be asserted in an action brought pursuant to 42 U.S.C. § 1983, the District Court should dismiss Royce’s petition. Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 1 of 9
Page 2 of 9 B ACKGROUND The State of Florida has charged Royce with attempted first-degree murder in Leon County Case No. 2025CF001319. In his petition, Royce asserts four grounds: (1) the probable cause affidavit for his arrest warrant was not signed, (2) the trial court denied bond during his first appearance, (3) the State of Florida failed to arraign him timely, and (4) he has had little or no communication with his attorney. Royce also asserts that while confined, the staff have interfered with Royce’s mail and religious materials. Royce also alleges that the jail is unsanitary and the staff refuses to provide him recreation and medical treatment. Royce seeks release from pre-trial detention, and an injunction against his accuser, and damages of $4,000. D ISCUSSION A. The Younger Abstention Doctrine “When a petitioner seeks federal habeas relief prior to a pending state criminal trial the petitioner must satisfy the ‘Younger abstention hurdles’ before the federal courts can grant such relief.” Hughes v. Att’y Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 2 of 9
Page 3 of 9 Gen. of Fla., 377 F.3d 1258, 1262 (11th Cir. 2004) (quoting Kolski v. Watkins, 544 F.2d 762, 766 (5th Cir. 1977)). In Younger, the Supreme Court held that federal courts should not enjoin a pending state criminal proceeding unless an injunction is necessary to prevent great and immediate irreparable injury. 401 U.S. at 53–54. As the Supreme Court stated: “the normal thing to do when federal courts are asked to enjoin pending proceedings in state courts is not to issue such injunctions.” Id. at 45. The Supreme Court’s Younger decision was based on a strong federal policy against federal-court interference with pending state judicial proceedings. Id. at 44; Green v. Jefferson Cnty. Comm’n, 563 F.3d 1243, 1250 (11th Cir. 2009). Under Younger, a district court should abstain from interfering with ongoing state proceedings when “(1) state proceedings, judicial in nature, are pending; (2) the state proceedings involve important state interests; and (3) the state proceeding afford adequate opportunity to raise constitutional issues.” Johnson v. Florida, 32 F.4th 1092, 1099 (11th Cir. 2022); see Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432 (1982). “There are three narrow exceptions to the abstention doctrine: (1) there is evidence of state proceedings Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 3 of 9
Page 4 of 9 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. Generally, the Younger analysis is conducted in three steps. First, federal courts consider whether a qualifying state-court proceeding is pending. Tokyo Gwinnett, LLC v. Gwinnett Cnty., 940 F.3d 1254, 1267– 68 (11th Cir. 2019). If so, federal courts then consider whether it is appropriate to abstain under the factors set forth in Middlesex. Id. at 1268. If abstention appears to be appropriate, federal courts then must determine whether any exception to Younger applies. Middlesex, 457 U.S. at 435; Kugler v. Helfant, 421 U.S. 117, 123–25 (1975). 1. There is an Ongoing, Qualifying State Proceeding Florida is currently prosecuting Royce for attempted first degree murder in Leon County Case No. 2025CF001319. Accordingly, the first Younger criterion is satisfied. 2. The Middlesex Factors Weigh in Favor of Abstention At the second step of the Younger analysis, the District Court must consider whether: (1) the federal action would interfere with ongoing qualifying state judicial proceedings; (2) the state proceedings implicate Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 4 of 9
Page 5 of 9 important state interests; and (3) the underlying state proceedings afford litigants an adequate opportunity to raise federal claims. Tokyo Gwinnett, LLC, 940 F.3d at 1267–68. (a). Interference with State Judicial Proceedings “In order to decide whether the federal proceeding would interfere with the state proceeding,” the court looks “to the relief requested and the effect it would have on the state proceedings. The relief sought need not directly interfere with an ongoing proceeding or terminate an ongoing proceeding in order for Younger abstention to be required.” 31 Foster Children v. Bush, 329 F.3d 1255, 1276 (11th Cir. 2003) (citations omitted). Royce requests that this court void the state court’s detention order, release Royce from custody, and impose an injunction on Royce’s accuser. This relief necessarily would conflict with, and would obviate, Florida’s pending court proceedings. (b). Important State Interests The State of Florida’s criminal prosecution of Royce implicates important state interests. Younger, 401 U.S. at 41–44. The adjudication of criminal cases—which is a facet of crime prevention—is an important Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 5 of 9
Page 6 of 9 state interest, particularly when there are victims involved. Calderon v. Thompson, 523 U.S. 538, 556 (1998); United States v. Salerno, 481 U.S. 739, 750 (1987). “[P]reventing and dealing with crime is much more the business of the States than it is of the Federal Government . . . .” Patterson v. New York, 432 U.S. 197, 201 (1977). The “State has a strong sovereign interest in ensuring public safety and criminal justice within its territory, and in protecting all crime victims. . . . The State also has a strong interest in ensuring that criminal offenders . . . are appropriately punished and do not harm others in the State.” Oklahoma v. Castro- Huerta, 597 U.S. 629, 651 (2022). Thus, there is a “strong judicial policy against interference with state criminal proceedings.” Arizona v. Manypenny, 451 U.S. 232, 243 (1981). Accordingly, the second Middlesex factor also weighs in favor of abstention. (c). Adequate Opportunity to Raise Federal Claims Finally, Royce will have an adequate opportunity to raise his federal claims in state courts. In order for Royce to show he lacks an adequate opportunity to raise his claims, he must assert that he is procedurally prevented from raising the claims pretrial, during trial, or at a subsequent stage of the criminal proceedings. See Johnson, 32 F.4th Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 6 of 9
Page 7 of 9 at 1101 (“what matters is whether the plaintiff is procedurally prevented from raising his constitutional claims in the state courts.”) (citing Pompey v. Broward Cnty., 95 F.3d 1543, 1551 (11th Cir. 1996)). Royce has not alleged any facts showing that he is procedurally prevented from challenging the trial court’s decision to detain him without bond, to challenge the sufficiency of the warrants, and to challenge his counsel’s conduct. Indeed, the underlying state criminal case affords Royce adequate opportunities to raise the claims he seeks to assert in his petition. See Flores v. State 66 So. 3d 1094, 1094 (Fla. 5th DCA 2011) (granting state habeas relief where trial court failed to make the requisite finding to support a denial of bond); Johnson, 32 F.4th at 1100 (noting that Florida law permits a defendant to file a writ of prohibition and a direct appeal to challenge an alleged violation of the defendant’s Sixth Amendment right to a speedy trial). Furthermore, if Royce believes that his attorney is deficient in some respect, Royce may request representation by another attorney. Accordingly, the third Middlesex factor also weighs in favor of abstention. Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 7 of 9
Page 8 of 9 3. There Are No Applicable Exceptions to Younger Royce has not alleged bad faith, harassment, or any other extraordinary circumstances that would make abstention inappropriate. “[T]he cost, anxiety, and inconvenience of having to defend against a single prosecution alone do not constitute ‘irreparable injury’” that would warrant federal interference in a state criminal proceeding. Kugler, 421 U.S. at 124. Accordingly, for this reason, the District Court should dismiss Royce’s petition. B. Royce’s Constitutional Challenges to the Conditions of His Confinement Constitutional challenges to the conditions of Royce’s confinement—e.g., Royce’s claim for damages based on the (1) denial of medical care, (2) denial of recreation time, (3) denial of mail privileges; and (4) the unsanitary condition of the dorms in the jail—are properly brought in an action pursuant to 42 U.S.C. § 1983. McKinnis v. Mosely, 693 F.2d 1054, 1057 (11th Cir. 1982). Because these claims must be brought in a civil action, the District Court should dismiss these claims without prejudice. Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 8 of 9
Page 9 of 9 CONCLUSION For the reasons set forth above, the undersigned respectfully RECOMMENDS that the District Court: 1. DISMISS without prejudice Petitioner Samuel David Royce’s petition for Writ of Habeas Corpus under 28 U.S.C. § 2241. 2. DIRECT the clerk of the court to close the case file. At Pensacola, Florida, this 8th day of December, 2025. /s/ Michael J. Frank Michael J. Frank United States Magistrate Judge NOTICE TO THE PARTIES The District Court referred this case to a magistrate judge to make recommendations regarding dispositive matters. See N.D. Fla. Loc. R. 72.2; see also 28 U.S.C. § 636(b). Objections to this report and recommendation (“R&R”) must be filed within fourteen days of the date of the R&R. A party who fails to object to the magistrate judge’s findings or recommendations contained in this R&R 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. If Plaintiff disputes the accuracy of any facts taken from judicially-noticed documents, or if they otherwise wish to be heard on the propriety of the District Court taking judicial notice of those facts, they must raise this issue in an objection to this R&R. Case 4:25-cv-00358-TKW-MJF Document 21 Filed 12/08/25 Page 9 of 9
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