The opinion
NOT FOR PUBLICATION
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
CAMDEN VICINAGE
i HONORABLE KAREN M. WILLIAMS
MYRON N, CRISDON,
Civil Action
Plaintiff, 7 No. 25-18226 (KMW-MIS)
Vv. :
!
BRTT.B oe AND ORDER
Defendants.
!
THIS MATTER comes before the Court by way of Plaintiff Myron N. Crisdon’s
(“Plaintiff’} Application to Proceed in District Court Without Prepaying Fees or Costs (“IFP
Application”) (Dkt. No. 6-2) pursuant to 28 U.S.C, § 1915(a)(1) and Plaintiff’s Motion for a
Temporary Restraining Order (“TRO”) (Dkt. No. 7); and
THE COURT NOTING that, having reviewed Plaintiff's IFP Application, Plaintiff
declares that he does not have a monthly income or expenses. (IFP Application 4 1, 8.) Plaintiff
does not have other liquid assets, nor does he list a spouse to contribute income or share in expenses
(id. Jf 1-8); and
THE COURT FINDING that because Plaintiff declares that he has no income, the Court
grants the IFP application. The Court is now required to screen the Complaint pursuant to 28
U.S.C. § 1915(e)(2)(B),! and dismiss any claim that is frivolous, malicious, fails to state a claim
for relief, or otherwise seeks relief from an immune defendant. For the reasons set forth below,
legal standard for dismissing a complaint for failure to state a claim pursuant to 28 U.S.C. § 1915(e)(2}03) □□□□
is the same as that for dismissing a complaint pursuant to Federal Rule of Civil Procedure 12(b)(6)." Sehreane v.
Seana, 506 F, App’x 120, 122 Gd Cir. 2012).
Plaintiff's Complaint is DISMISSED with prejudice and Plaintiff's Motion for a TRO 1s
DENIED.
I. BACKGROUND
In his Amended Complaint, Plaintiff alleges that he is the defendant in a pending criminal
proceeding before the Camden Municipal Court arising from Municipal Complaint No. 0408-S-
2024-004687. (Dkt. No. 6.) Plaintiff names the Camden Municipal Court and a municipal court
judge as respondents and seeks a writ of mandamus compelling dismissal of the municipal
prosecution. (d. at 1.) Plaintiff alleges that he filed a motion to dismiss in the municipal court on
October 17, 2025, that court personnel initially refused to accept the filing before later accepting
it, and that the presiding municipal court judge proceeded with a hearing without first reviewing
or deciding the motion. (/d. at 1-2.) Plaintiff further alleges that the municipal court has failed to
provide adequate resources to pro se litigants, thereby denying him meaningful access fo the courts
and violating his federal constitutional rights. (7d, at 2.)
As relief, Plaintiff asks this Court to issue a writ of mandamus directing the municipal court
to dismiss the underlying municipal prosecution with prejudice, vacate all proceedings occurring
after the filing of his motion to dismiss, investigate the Camden Municipal Court Clerk’s Office,
stay all further municipal court proceedings, and award compensatory, treble, and punitive
damages together with any additional relief the Court deems appropriate. (Ud. at 3.)
After commencing this action, Plaintiff filed the pending TRO Motion. (Dkt. No. 7.) □
Therein, Plaintiff represents that he appeared before the Camden Municipal Court on January 16,
2026, informed the municipal court that this federal action was pending, objected to further
proceedings, and requested that the municipal court stay the case. Gd. at 1-2.) According to
Plaintiff, the municipal court denied that request, scheduled the matter for trial, and advised
Plaintiff that he could face incarceration and monetary penalties if convicted. (/d. at 2.) Plaintiff
now asks this Court to immediately enjoin the municipal proceedings pending resolution of this
action, (Id, at 3-4.)
The matter is therefore before the Court for screening pursuant to 28 U.S.C,
§ 1915(e)(2)(B) and for disposition of Plaintiff's request for emergency injunctive relief.
I. LEGAL STANDARD
a. Screening Under 28 U.S.C, § 1915(e)(2)(B).
Under 28 U.S.C, § 1915(a), a district court may authorize a litigant to proceed without
prepayment of fees upon a showing of financial inability to pay. However, granting in forma
pauperis status does not relieve the Court of its obligation to screen the complaint. Rather, the
Court must dismiss an action filed in forma pauperis at any time if it determines that the action
“) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (ili) seeks
monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B).
The legal standard governing dismissal under § 1915(e)(2)(B)Gi) is the same as the standard
applicable to a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). Tourscher v.
McCullough, 184 F.3d 236, 240 (3d.Cir. 1999). Accordingly, to survive screening, a complaint
must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible
on its face.” Ashcroft v. Igbal, 556 U.S. 662, 678 (2009) (quoting Bell At. Corp. v. Twombly, 550
U.S. 544, 570 (2007)). Although the Court accepts well-pleaded factual allegations as true and
draws all reasonable inferences in the plaintiff's favor, it need not accept legal conclusions couched
as factual allegations. Igbal, 556 U.S. at 678-79,
Because Plaintiff proceeds pro se, the Court construes his pleadings liberally and holds
them “to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus,
551 U.S. 89, 94 (2007) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). Even so, “pro se
litigants still must allege sufficient facts in their complaints to support a claim.” Mala vy. Crown
Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013), A court “need not credit a pro se plaintiffs
‘bald assertions’ or ‘legal conclusions,’” Morse v. Lower Merion Sch, Dist., 132 F.3d 902, 906 (3d
Cir. 1997) (quoting In re Burlington Coat Factory Securities Litigation, 114 F.3d 1410, 1429-30
(3d Cir. 1997)).
Finally, before dismissing a complaint under § 1915(e)(2)(B), a district cout generally
should permit amendment unless amendment would be inequitable or futile. Grayson v. Mayview
State Hosp., 293 F.3d 103, 108, 110-11 (@d Cir. 2002).
b. TROs and Preliminary Injunctions
“A preliminary injunction is an extraordinary remedy never awarded as of right.” Winter
Nat. Res. Def. Council, Inc., 555 U.S. 7, 24 (2008). A party seeking preliminary injunctive relief
bears the burden of establishing: ‘(1) a likelihood of success on the merits”; (2) that it will “suffer
irreparable harm” if the injunction is denied; (3) that granting preliminary relief will not result in
even greater harm to the nonmoving party; and (4) that “the public interest,” Reilly v. City of
Harrisburg, 858 F.3d 173, 176 (3d Cir. 2017),
The first two factors are “gateway factors.” Reilly, 858 F.3d at 179. If the movant fails to
establish cither a likelihood of success on the merits or irreparable harm, preliminary injunctive
relief must be denied. Id.; see also Adams v. Freedom Forge Corp., 204 F.3d 475, 484 (3d Cir.
2000). Only if the movant satisfies both gateway requirements does the Court consider the
remaining factors and determine whether, on balance, the extraordinary remedy of injunctive relief
is warranted, Reilly, 858 F.3d at 179, Because a TRO is governed by the same substantive standard
as a preliminary injunction, courts evaluate requests for either form of relief under this four-factor
framework. See NutraSweet Co. v. Vit-Mar Enters., Inc., 176 F.3d 151, 153 (3d Cir. 1999); Fed.
R, Civ, P. 65.
IW. DISCUSSION
a. Plaintiff Cannot Obtain Federal Mandamus Against a State Court or State
Judge.
Plaintiff styles his pleading as a “Petition for Writ of Mandamus” and invokes 28 U.S.C.
§ 1361 as the basis for this Court's jurisdiction. Specifically, Plaintiff asks this Court to compel a
Camden Municipal Court judge to dismiss the pending municipal prosecution against him, vacate
prior municipal court proceedings, investigate the Camden Municipal Court Clerk’s Office, and
stay all future proceedings in the municipal action,
Plaintiff's reliance on § 1361 is misplaced. Congress has conferred mandamus jurisdiction
upon the district courts only “to compel an officer or employee of the United States or any agency
thereof to perform a duty owed to the plaintiff.” 28 U.S.C. § 1361. By its plain language, the statute
applies only to federal officers and agencies; it does not authorize federal district courts to issue
writs of mandamus directing state courts, state judges, or other state officials in the performance
of their duties. See In re Wolenski, 324 F.2d 309, 309 (3d Cir, 1963).
Here, every form of mandamus relief Plaintiff requests is directed at state actors. Plaintiff
asks this Court to compel a Camden Municipal Court judge to dismiss his municipal complaint,
declare prior municipal court proceedings void, investigate the Camden Municipal Court Clerk’s
Office, and halt all further proceedings in the pending state prosecution. Those requests necessarily
seek to direct the actions of a state court and state judicial officers in the exercise of their official
duties. Section 1361 provides no jurisdiction for such relief,
Nor may Plaintiff circumvent this jurisdictional limitation by characterizing the requested
relief as necessary to vindicate his constitutional rights. Although Plaintiff alleges violations of
due process, denial of access to the courts, and other constitutional deprivations, those allegations
do not expand the Court’s mandamus jurisdiction beyond the limits established by Congress. See
Inve Wolenski, 324 F.2d at 309. Federal district courts are courts of limited jurisdiction and possess
no supervisory authority over state courts apart from that expressly authorized by federal law.
Accordingly, because Plaintiff seeks a writ directing a state court and state judicial officers
to perform—or refrain from performing—official acts in an ongoing municipal proceeding, this
Court lacks jurisdiction under 28 U.S.C. § 1361 to grant the requested mandamus relief, The
Complaint therefore fails as a matter of law insofar as it seeks relief under the federal mandamus
statute.
b. Younger Abstention Independently Bars the Requested Relief.
Even assuming Plaintiff could overcome the jurisdictional defect discussed above, the
Court would nevertheless decline to exercise jurisdiction under the abstention doctrine established
in Younger v. Harris, 401 U.S. 37 (1971),
Under Younger, federal courts ordinarily must refrain from interfering with ongoing stale
criminal proceedings absent extraordinary circumstances. Younger, 401 U.S. at 43-45. The
doctrine “espouse[s] a strong federal policy against federal-court interference with pending state
judicial proceedings absent extraordinary circumstances.” Middlesex Cnty. Ethics Comm. v.
Garden State Bar Ass’n, 457 U.S. 423, 431 (1982). Although the Supreme Court has subsequently
clarified that Younger abstention applies only in limited categories of cases, ongoing state criminal
prosecutions remain the core circumstance in which federal abstention is warranted. Sprint
Comme’ns, Inc. v. Jacobs, 371 U.S. 69, 72-73 (2013).
The Third Circuit has recognized that Younger abstention is appropriate where: (1) there is
“an ongoing state judicial proceedings”; (2) the state proceedings “implicate important state
interests”; and (3) the state proceedings afford “an adequate opportunity to raise the same
constitutional challenges presented in the federal action.” ACRA Turf Club, LLC v. Zanzuccki, 748
F.3d 127, 138 Gd Cir. 2014) (citing Middlesex, 457 U.S. at 432), When these conditions are
satisfied, abstention is mandatory unless the plaintiff demonstrates bad faith, harassment, or
another extraordinary circumstance that would make abstention inappropriate. Sprint, 571 U.S. at
77; Younger, 401 U.S, at 53-54,
Each of those requirements is satisfied here. First, Plaintiff expressly alleges that the
municipal prosecution remains pending. Indeed, Plaintiff's Emergency Motion for a TRO
represents that, on January 16, 2026, the Camden Municipal Court denied his request for a stay
and scheduled the matter for trial. Thus, there is no dispute that an ongoing state judicial
proceeding exists.
Second, the municipal prosecution plainly implicates important state interests. “The 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.” Kelly v. Robinson, 479 U.S. 36, 49 (1986); see also Younger, 401 U.S. at 44-45, That
interest extends to municipal prosecutions brought pursuant to New Jersey law.
Third, Plaintiff has not plausibly alleged that the municipal proceeding prevents him from
presenting his federal constitutional arguments. To the contrary, the Complaint reflects that
Plaintiff has repeatedly appeared before the municipal court, filed motions, objected on
constitutional grounds, and sought dismissal of the municipal complaint. Likewise, Plaintiff
alleges that he informed the municipal judge of his constitutional objections and of this federal
action during the January 16, 2026 proceeding. These allegations demonstrate that Plaintiff has
had, and continues to have, the opportunity to present his constitutional arguments in the state
proceeding and, if necessary, through New Jersey’s appellate process, See Juidice v. Vail, 430 U.S,
327, 337 (1977) (“[A]ppellees need be accorded only an opportunity to fairly pursue their
constitutional claims in the ongoing state proceedings.”).
Nor has Plaintiff alleged facts bringing this case within any recognized exception to
Younger. The exceptions for bad-faith prosecution, harassment, or other extraordinary
circumstances are “narrow” and apply only in exceptional situations. See ACRA Turf Club, LEG,
748 F.3d at 135-36, Plaintiff principally alleges that the municipal court failed to rule on his motion
to dismiss before conducting a hearing, that court personnel initially declined to accept one of his
filings, and that the municipal court denied his request to stay the proceedings after learning of this
federal action. Even accepting those allegations as true, they concern alleged procedural errors in
an ongoing criminal proceeding—not the sort of extraordinary circumstances that justify federal
intervention under Younger. See Kugler vy. Helfant, 421 U.S, 117, 124-25 (1975) (“Only in cases
of proven harassment or prosecutions undertaken by state officials in bad faith without hope of
obtaining a valid conviction . ., is federal injunctive relief against state prosecutions appropriate.”).
Ultimately, Plaintiff asks this Court to stay his pending municipal prosecution, direct the municipal
court to dismiss the charges against him, and otherwise supervise the conduct of the state
proceedings, Those requests are precisely the type of federal interference that Younger prohibits.
Accordingly, even if this Court possessed jurisdiction to entertain Plaintiff's claims, it
would abstain from exercising that jurisdiction under Younger and dismiss the Amended
Complaint.
ce. The Anti-Injunction Act Independently Prohibits the Requested
Injunction.
Plaintiff's request for emergency relief is independently foreclosed by the Anti-Injunction
Act, Through both his Complaint and his Emergency Motion for a TRO, Plaintiff asks this Court
to stay all proceedings in the pending Camden Municipal Court prosecution until this federal action
is resolved. He likewise requests that this Court vacate prior municipal court proceedings and
prohibit the municipal court from taking further action in his criminal case. Congress has expressly
limited the authority of federal courts to interfere with pending state judicial proceedings. The
Anti-Injunction Act provides: “A court of the United States may not grant an injunction to stay
proceedings in a State court except as expressly authorized by Act of Congress, or where necessary
in aid of its jurisdiction, or to protect or effectuate its judgments.” 28 U.S.C, § 2283,
The Supreme Court has repeatedly recognized that the Anti-Injunction Act is “an absolute
prohibition against enjoining state court proceedings, unless the injunction falls within one of three
specifically defined exceptions.” Ail. Coast Line R.R. Co. v. Bhd. of Locomotive Eng’rs, 398 US.
281, 286 (1970). Because the statute embodies “the fundamental constitutional independence of
the States and their courts,” its exceptions are construed narrowly and “should not be enlarged by
loose statutory construction.” Id, at 287; see also Smith v. Bayer Corp., 564 U.S. 299, 306 2011)
(“The Act’s core message is one of respect for state courts,”). None of the Act’s three exceptions
apply here.
First, Plaintiff identifies no Act of Congress expressly authorizing this Court to enjoin his
ongoing municipal prosecution, Although the Complaint cites 42 U.S.C. § 1983, the relief Plaintiff
principally seeks is a writ of mandamus directing a state court to dismiss pending criminal charges
and stay further proceedings. As discussed above, § 1361 affords no such authority because it
applies only to federal officers and agencies. Moreover, even where § 1983 may qualify as an
“expressly authorized” exception under Mitchum y. Foster, 407 U.S, 225, 242-43 (1972), federal
couits remain subject to the equitable restraint imposed by Younger. See Trainor v. Hernandez,
431 U.S. 434, 444 (1977); Mitchum, 407 U.S. at 243 (recognizing that principles of equity, comity,
and federalism continue to constrain federal injunctive relief under § 1983).
Second, an injunction is not “necessary in aid” of this Court's jurisdiction. That narrow
exception generally applies where a federal court has pteviously assumed jurisdiction over
property or other proceedings in which its jurisdiction would otherwise be impaired. See Al. Coast
Line, 398 U.S. at 295; Vendo Co. y. Lektro-Vend Corp., 433 U.S. 623, 641-42 (1977) (plurality
opinion). This case presents, no such circumstances. Plaintiff simply asks this Court to intervene
in an ongoing municipal prosecution over which the state court properly exercises jurisdiction,
Third, an injunction is not necessary “to protect or effectuate” any judgment of this Court.
Commonly referred to as the “relitigation exception,” this provision permits a federal court to
prevent relitigation of claims or issues previously resolved by a final federal judgment. See Chick
Kam Choo v. Exxon Corp., 486 U.S. 140, 146-47 (1988). There is no prior federal judgment
concerning Plaintiff's municipal prosecution, and thus no judgment for this Court to protect.
Ultimately, Plaintiff requests precisely the relief that § 2283 generally prohibits: an order
halting an ongoing state judicial proceeding. Because none of the Anti-Injunction Act’s narrowly
construed exceptions applies, this Court lacks statutory authority to issue the requested injunction.
This provides an additional and independent reason why Plaintiffs request for a TRO and
preliminary injunctive relief must be denied.
d. Even Construing the Complaint as Asserting Claims Under 42 U.S.C, §
1983, Plaintiff Fails to State a Plausible Federal Claim.
Because Plaintiff proceeds pro se, the Court has liberally construed the Complaint.
Although styled as a petition for a writ of mandanuus, the pleading repeatedly alleges violations of
Plaintiff's federal constitutional rights and cites 42 U.S.C. § 1983. Accordingly, the Court
considers whether the Complaint states a plausible claim for relief under § 1983, It does not.
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Section 1983 provides a cause of action against any “person” who, acting under color of
state law, deprives another of rights secured by the Constitution or laws of the United States. 42
U.S.C. § 1983. To state a claim, a plaintiff must allege “(1) the violation of a right secured by the
Constitution and laws of the United States, and (2) that the alleged deprivation was committed or
caused by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988). Even
liberally construed, Piaintiff’s allegations fail for several independent reasons,
First, to the extent Plaintiff seeks relief against the Camden Municipal Court itself, the
Complaint fails because a state court is not a “person” subject to suit under § 1983. See Will v.
Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989) (holding that neither a State nor its officials
acting in their official capacities are “persons” under § 1983 for purposes of damages); Johnson ¥.
State of N.J., 869 F. Supp. 289, 296-97 (D.N.J. 1994) (holding that New Jersey courts are arms of
the State and therefore not subject to suit under § 1983), aff'd, 66 F.3d 311 (3d Cir. 1995), Because
the Camden Municipal Court is a component of New Jersey’s judicial system, it is not a proper
defendant under § 1983.
Second, to the extent Plaintiff challenges the actions of the municipal court judge, those
claims are barred by the doctrine of absolute judicial immunity. It is well settled that judges are
“absolutely immune” from suits arising out of acts performed in their judicial capacity, even where
those acts are alleged to have been erroneous, malicious, or in excess of authority. Stunp v.
Sparkman, 435 U.S. 349, 354 (1978), Mireles v. Waco, 502 U.S. 9, 10 (1991), Judicial immunity
is overcome only where a judge acts in the clear absence of all jurisdiction or performs nonjudicial
acts. Mireles, 502 U.S. at 11-12. None of Plaintiff’s allegations fails within either exception.
Plaintiff alleges that the municipal judge failed to rule on a pending motion, dented his request to
stay the proceedings, continued the prosecution, scheduled a trial, and advised Plaintiff of the
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potential penalties he faced if convicted, Each of these alleged actions is quintessentially judicial
in nature and occurred during the course of an ongoing criminal proceeding over which the
municipal court plainly possessed subject-matter jurisdiction, Consequently, the municipal judge
is absolutely immune from Plaintiffs claims.
Finally, Plaintiff's remaining constitutional allegations consist largely of conclusory
assertions that municipal court personnel denied him due process, obstructed access to the courts,
committed misconduct, or engaged in unconstitutional practices. Although Plaintiff alleges that
court personnel initially declined to accept one of his filings, he also acknowledges that the filing
was ultimately accepted by the municipal court. Beyond these allegations, the Complaint contains
no non-conclusory factual matter plausibly showing that any defendant deprived Plaintiff of a
federally protected right. See Igbal, 556 U.S. at 678. Nor does Plaintiff allege facts demonstrating
the “actual injury” necessary to state a constitutional claim for denial of access to the courts. See
Lewis v. Casey, 518 U.S. 343, 349-53 (1996) (holding that an access-to-courts claim requires a
showing that the alleged interference hindered pursuit of a nonfrivolous legal claim); Monroe □□
Beard, 536 F.3d 198, 205-06 (3d Cir. 2008) (same).
At bottom, Plaintiff disagrees with the manner in which the municipal court has managed
his petiding criminal case and seeks federal intervention to overturn the state court’s rulings.
Section 1983 does not provide a vehicle for this Court to supervise ongoing state criminal
proceedings or review alleged errors committed therein, Accordingly, even liberally construing
the Complaint as asserting claims under § 1983, Plaintiff fails to state a claim upon which relief
may be granted, providing an additional basis for dismissal under 28 U.S.C. § 191 5(e)(2)(B).
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e. Plaintiff Is Not Entitled to a TRO or Preliminary Injunction.
Plaintiff also moves for a TRO and preliminary injunction staying all proceedings in the
pending Camden Municipal Court prosecution. Specifically, Plaintiff asks this Court to
immediately enjoin the municipal court from conducting further proceedings until this federal
action is resolved.
Plaintiff cannot satisfy the first—and most important—-threshoid requirement. As
discussed above, this Court lacks authority under 28 U.S.C. § 1361 to issue a writ of mandamus
directing a state court or state judicial officer to act. Moreover, Plaintiff's requested relief is
independently barred by the Younger abstention doctrine and by the Anti-Injunction Act, 28 U.S.C.
§ 2283. Finally, even liberally construing the Complaint as asserting claims under 42 U.S.C.
§ 1983, Plaintiff has failed to state a plausible claim for relief because the named defendants are
either not subject to suit under § 1983 or are entitled to absolute judicial immunity. Accordingly,
Plaintiff has not demonstrated any likelihood of success on the merits.
Because Plaintiff cannot establish a likelihood of success, the Court need not engage in an
extended analysis of the remaining factors. See Reilly, 858 F.3d at 179. Although Plaintiff asserts
that he faces the prospect of criminal prosecution, incarceration, and monetary penalties if the
municipal proceedings continue, those consequences arise from the ordinary operation of the
pending state criminal process and do not justify federal intervention where Congress and the □
Supreme Court have expressly limited the authority of federal courts to interfere with ongoing
state proceedings. See Younger, 401 U.S. at 43-45,
The remaining factors likewise do not favor injunctive relief, Enjoining an ongoing
municipal criminal prosecution would substantially interfere with New Jersey’s administration of
its criminal justice system and would undermine the principles of comity and federalism that
2B
underlie both Younger and the Anti-Injunction Act. See Middlesex Cnty. Ethics Comm., 457 U.S.
at 431 (recognizing the “strong federal policy against federal-court interference with pending state
judicial proceedings”); Al. Coast Line R.R. Co., 398 U.S. at 287 (explaining that the Anti-
Injunction Act reflects “the fundamental constitutional independence of the States and their
courts”). The public interest is therefore served by permitting the state courts to adjudicate
Plaintiff’s criminal case in the ordinary course, subject to the review procedures provided by New
Jersey law. Because Plaintiff has failed to establish the threshold requirements for extraordinary
injunctive relief, his Emergency Motion for a TRO and Preliminary Injunction will be denied
f. Leave to Amend Would Be Futile.
Ordinarily, when a district court dismisses a pro se compiaint for failure to state a claim,
the plaintiff should be afforded an opportunity to amend unless amendment would be inequitable
or futile. Grayson, 293 F.3d at 110-11; see also Phillips v. Cnty. of Allegheny, 515 F.3d 224, 245
(3d Cir, 2008). Amendment is futile where the amended complamt “would fail to state a claim
upon which relief could be granted.” In re Burlington Coat Factory Sec. Litig., 114 F.3d at 1434.
The Court concludes that amendment would be futile here because the defects in Plaintiff's
pleading are legal, not factual. The gravamen of the Complaint is Plaintiff's request that this Court
intervene in an ongoing municipal criminal proceeding by directing the Camden Municipal Court
and its judge to dismiss the pending charges, vacate prior proceedings, and stay all further action
in the case. No additional factual allegations could transform the Camden Municipal Court or its
judicial officers into federal officers subject to mandamus jurisdiction under 28 ULS.C. § 1361.
Likewise, no amendment could eliminate the applicability of Younger abstention so jong as the
underlying municipal prosecution remains pending, nor could additional factual allegations bring
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Plaintiff's request for a federal stay of those proceedings outside the scope of the Anti-Injunction
Act. See Younger, 401 U.S. at 43-45 (1971); 28 U.S.C, § 2283,
Nor could amendment cure the remaining deficiencies identified above. The municipal
is not a proper defendant under 42 U.S.C. § 1983, and the challenged conduct of the
municipal judge—ruling on motions, managing the proceedings, denying a stay, and scheduling
trial—falls squarely within the scope of absolute judicial immunity. These legal impediments do
not depend upon the particular factual allegations of the Complaint and therefore cannot be
remedied through repleading.
Finally, to the extent Plaintiff seeks federal review of alleged constitutional exrors
committed during the course of his municipal prosecution, those issues may be raised im the state
proceedings themselves and, if appropriate, through New Jersey's appeilate process. This Court
cannot exercise supervisory authority over an ongoing state criminal proceeding simply because
Plaintiff believes the municipal court has erred. Because the deficiencies identified in this Opinion
from settled jurisdictional, statutory, abstention, and immunity principles rather than
insufficient factual pleading, permitting amendment would serve no useful purpose.
Accordingly, the Complaint will be dismissed with prejudice.
CONSEQUENTLY, for all the foregoing reasons, and for good cause shown;
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ORDER
IT 1S on this day of August, 2026, hereby
ORDERED that Plaintiff's IFP Application (Dkt. No. 6-2) is GRANTED; and further
ORDERED that Plaintiff's Amended Complaint (Dkt. No. 6) is DISMISSED WITH
PREJUDICE; and further
ORDERED that Plaintiff's Motion for TRO (Dkt, No. 7) is DENIED; and further
ORDERED that the Clerk of the Court shall mark this matter CLOSED and serve a copy
of this Order upon Plaintiff by regular U.S. mail.
on,
he ON
KARIN M. WILLIAMS
UNITED STATES DISTRICT JUDGE
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