GUZMAN JUNIOR v. ANDROSCOGGIN COUNTY JAIL

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UNITED STATES DISTRICT COURT
DISTRICT OF MAINE
JESUS MIGUEL
GUZMAN JUNIOR,
Petitioner,
v.
ANDROSCOGGIN COUNTY JAIL,
Defendant.
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2:25-cv-00650-SDN
AMENDED ORDER AFFIRMING RECOMMENDED DECISION
On January 2, 2026, the Magistrate Judge recommended dismissing Petitioner’s
habeas petition after preliminary review pursuant to Rule 4 of the Rules Governing
Section 2254 Cases, Younger v. Harris, 401 U.S. 37 (1971), and Petitioner’s failure to
follow certain procedural requirements for filing petitions on behalf of a third party. ECF
No. 2. The Magistrate Judge notified the parties that failure to object by January 16, 2026,
would waive their right to de novo review and appeal. Mr. Guzman Junior attempted to
file an objection to the Recommended Decision by emailing the filing to the Clerk of
Court,1 but the Clerk did not docket it because he did not follow the local rules for pro se
electronic filers.
Nonetheless, even if the Court considers Petitioner’s Objection, which it dockets
now, ECF No. 5-1, after conducting a de novo review 	of the Magistrate Judge’s
Recommended Decision, see Fed. R. Civ. P. 72(b)(2), the Court agrees with the findings
and legal conclusions set 	forth in the Decision. 	Mr. Guzman Junior’s position 	is
1 Mr. Guzman Junior informed the Court of this unsuccessful filing in a subsequent motion to vacate the
judgment that he filed after this Court affirmed the Recommended Decision and granted dismissal. See ECF
No. 5. Because the Court has now determined de novo that dismissal is warranted, the motion to vacate the
judgment is dismissed as moot.
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predicated on his alleged status as a “next friend” of Mr. Fitzherbert, who currently is
incarcerated at the Androscoggin County Jail. Most frequently, “next friends” appear in
court on 	behalf of detained 	persons who are unable, 	usually 	because of 	mental
incompetence or inaccessibility, to seek relief themselves. See Whitmore v. Arkansas, 495
U.S. 149, 	162 	(1990). 	But “next friend” standing is not “granted automatically to
whomever seeks to pursue an action on behalf of another.” Id. at 163. The petitioner must
advance an “adequate explanation” as to why the real party in interest cannot appear on
his own behalf. Id. Nothing in the record or Mr. Guzman Junior’s petition indicates why
Mr. Fitzherbert is foreclosed from prosecuting his own action. Furthermore, as the
Magistrate Judge points out, Younger preclusion prohibits federal courts such as this one
from intruding into ongoing state prosecutions. See Sprint Commc’ns, Inc. v. Jacobs, 571
U.S. 69, 78 (2013) (noting Younger “preclude[s] federal intrusion into ongoing state
criminal prosecutions”). Because Mr. Guzman Junior’s petition appears to take issue with
Mr. Fitzherbert’s continued detention for an underlying state criminal case, this Court is
constrained from interfering.
Accordingly, 	the 	Court 	AFFIRMS 	and 	ADOPTS 	the 	Magistrate 	Judge’s
Recommended Decision. ECF No. 2. The petition for habeas relief under 28 U.S.C. § 2254
is DISMISSED. ECF No. 1. Petitioner’s motion to vacate the judgment is DISMISSED
AS MOOT. ECF No. 5. The Court further ORDERS that no certificate of appealability
should issue in the event the Petitioner files a notice of appeal because there is no
substantial showing of the denial of a constitutional right within the meaning of 28 U.S.C.
§ 2253(c)(2).
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S O ORDERED.
Dated this 18th day of May, 2026.
/s/ Stacey D. Neumann
U NITED S TATES D ISTRICT J UDGE
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