REED MATTILA v. LOWER MAKEFIELD TWP PA. POLICE DEPARTMENT et al, No. 3:2020cv14699 - Document 14 (D.N.J. 2021)
Court Description: MEMORANDUM OPINION filed. Signed by Judge Michael A. Shipp on 11/29/2021. (jem)
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REED MATTILA v. LOWER MAKEFIELD TWP PA. POLICE DEPARTMENT et al Doc. 14 Dockets.Justia.com under the Younger abstention doctrine. See Younger v. Harris, 401 U.S. 37 (1971). It is settled law that 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.” Moore v. Sims, 442 U.S. 415, 423 (1979). At the core of the Younger doctrine is the notion that federal courts should not interrupt state criminal proceedings. Id.; see also Younger, 401 U.S. at 43-44; Kelly v. Robinson, 479 U.S. 36, 49 (1986) (“[T]he States’ interest in administering their criminal justice systems free from federal interference is one of the most powerful of the considerations that should influence a court considering equitable types of relief.”). The Court is satisfied that Mattila will have an “adequate opportunity to raise federal claims,” as well as any defenses he may have, in his state court proceedings. Leverett, 2010 WL 606041, at *10.5 Accordingly, abstention is warranted under the Younger doctrine and the Court will not interfere with Mattila’s state court proceedings. Any request to do so is denied. To the extent Mattila’s criminal proceedings in the Commonwealth of Pennsylvania have already concluded, district courts lack subject matter jurisdiction to “reverse a state court decision or void its ruling.” Leverett, 2010 WL 606041, at *9 (citing Taliaferro v. Darby Twp. Zoning Bd., 458 F.3d 181, 192 (3d Cir. 2006)). 5 5
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