Logue v. The York County Court of Common Pleas et al

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
JAMES F. LOGUE,
Petitioner
V.
YORK COUNTY COURT OF COMMON
PLEAS, et al.,
Respondents
Civil No. 3:26-cv-230
(Judge Mariani)
ORDER
AND NOW, this d ¢ 	Jiil of February, 2026, upon preliminary review of the
petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254 (Doc. 1), and in accordance
with the Memorandum of the same date, IT IS HEREBY ORDERED THAT:
1. 	The application for leave to proceed in forma pauperis docketed on February
2, 2026 is DISMISSED as an improper form. 	(Doc. 2).
2. 	The application for leave to proceed in forma pauperis docketed on February
11, 2026 is GRANTED. 	(Doc. 6).
3. 	The petition for writ of habeas corpus (Doc. 1) is DISMISSED without
prejudice. 	See R. GOVERNING§ 2254 CASES R. 4.
4. 	The Clerk of Court is directed to CLOSE this case.
5. 	There is no basis for the issuan e.-e> 	ertificate of appealability. 	See 28
U.S.C. § 2253(c).
Robert D. 	a 	1
United States District Judge
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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
JAMES F. LOGUE , 	Civil No . 3:26-cv-230
Petit ioner
V.
YORK COUNTY COURT OF COMMON
PLEAS, et al.,
Respondents
(Judge Mariani)
MEMORANDUM
Petitioner James Logue ("Logue 1
t an inmate presently confined at the York County
Prison, filed the instant petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254 .
(Doc. 1). 	Prelim inary review of the petition has been undertaken , and , for the reasons set
forth below, the Court will dismiss the petition.
I. 	Background
According to Logue, he was arrested on December 5, 2025. 	(Doc. 1, at 3 ~ 11 ). An
electronic search via the Unified Judicial System of Pennsylvania Web Portal,
https://ujsportal.pacourts.us/CaseSearch, of Logue 1
s criminal docket, CP-67-MD-0002006-
2025, confirms that Logue was arrested on December 5, 2025, for indirect crim inal
contempt. 	See Commonwealth v. Logue , No. CP-67-MD-0002006-2025 (Pa. Ct. Com. Pl.
York Cnty.); see also Commonwealth v. Logue , No . CP -67-CR-0002948-2020 (Pa. Ct. Com .
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Pl. York Cnty .). 	Logue entered a guilty plea, and on, January 6, 2026, he was sentenced to
a term of probation of six months. 	See id .
On or about January 27, 2026 , Logue filed the instant habeas petition. (Doc. 1).
Logue asserts that he was arrested based on "false and fabricated arrest warrants." (Id. at
311 10-11 ). 	He sets forth claims of false imprisonment and illegal detention. 	(Id. at 1, 3, 5
111, 10, 14 , 23) . Logue also asserts that he filed a similar habeas petition in state court on
or about December 17, 2025, which remains pending . (Id. at 2, 5-618, 25 ; Doc . 1-1) .
II. 	Screening of Habeas Petitions
Under Rule 4 of the rules governing habeas corpus petitions under 28 U.S.C. §
2254 , a distr ict court must promptly review a petition and dismiss it if it is plain from the face
of the petition that the petitioner is not entitled to relief. 	28 U.S.C. § 2254 , Rule 4.
Ill. 	Discussion
Pursuant to 28 U.S.C. § 2254, a person in state custody may file an application for a
writ of habeas corpus challenging the fact or length of his or her confinement. 	See Preiser
v. Rodriguez , 411 U.S. 475 , 494 (1973); Tedford v. Hepting , 990 F.2d 745, 748 (3d Cir.
1993) . This section specifically provides that the person must be in custody pursuant to the
judgment of a state court. 	See 28 U.S .C. § 2254(a). 	It is apparent from the instant petition
that although Logue has been sentenced , he has relief available in the state court .
Generally, federal courts must adjudicate all cases and controversies that are
properly before them. 	New Orleans Pub . Serv., Inc. v. Council of City of New Orleans, 491
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U.S. 350 , 358 (1989). Abstention , however , "is the judicially created doctrine under which a
federal court wil l decline to exercise its jurisdiction so that a state court or state agency will
have the opportunity to decide the matters at issue ." Heritage Farms , Inc . v. Solebury Twp .,
671 F.2d 743 , 746 (3d Cir. 1982). In Younger v. Harris, 401 U.S . 37 (1971) , the United
States Supreme Court "established a principle of abstention when federal adjudication
would disrupt an ongoing state criminal proceed ing." 	Yang v. Tsui , 416 F.3d 199,202 (3d
Cir . 2005) (discussing Younger , 401 U.S. 37). The Younger Court based its decision on the
principles of comity and "the longstanding public policy against federal court interference
with state court proceedings ." 	Younger, 401 U.S. at 43 . Younger abstention applies when
the following three requirements are met: "(1) there are ongoing state proceedings that are
jud icial in nature; (2) the state proceedings implicate important state interests ; and (3) the
sta te proceedings afford an adequate opportunity to raise the federal cla ims ." Lazaridis v.
Wehmer, 591 F.3d 666, 670 (3d Cir . 2010) (quoting Addiction Specialists , Inc. v. Twp . of
Hampton , 411 F.3d 399, 408 (3d Cir. 2005)) .
Notably , even when all requirements are met , abstention is not appropr iate when the
following extraordinary circumstances exist: "(1 ) the state proceedings are being undertaken
in bad faith or for purposes of harassment or (2) some other extraordinary circumstances
exist, such as proceedings pursuant to a flagrantly unconstitutional statute .... " Schall v.
Joyce, 885 F.2d 101 , 106 (3d Cir . 1989) . These exceptions are to be narrowly construed .
Loftus v. Twp . of Lawrence Park, 764 F. Supp . 354 , 357 (W .D. Pa . 1991) .
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It is evident from the contents of the petition, and the state court electronic docket
sheet, that Logue is involved in ongoing criminal proceedings which implicate important
state interes ts, and in wh ich he can present any evidence of his innocence . Because there
is presently relief available at the state court level, there is an absence of extraord inary
circumstances that would warrant the intervention of a federal court. Thus, out of deference
to the state judicial process , it is appropriate to abstain from entertaining the petition .
Indeed, "[i]n no area of the law is the need for a federal court to stay its hand pending
completion of state proceedings more evident than in the case of pending criminal
proceedings ." Evans v. Court of Common Pleas, 959 F.2d 1227, 1234 (3d Cir . 1992) .
IV. 	Certificate of Appealability
Pursuant to 28 U.S.C. § 2253(c), unless a circuit justice or judge issues a certificate
of appealability ("COA "), an appeal may not be taken from a final order in a proceeding
under 28 U.S.C. § 2254 . A COA may issue only if the applicant has made a substantial
showing of the denial of a constitutional right. 	28 U.S.C. § 2253(c)(2) . "A petitioner satisfies
this standard by demonstrating that jurists of reason could disagree with the district court 's
resolution of his const itutional claims or that jurists could conclude the issues presented are
adequate to deserve encouragement to proceed further ." Miller-El v. Cockrell, 537 U.S . 322
(2003) . "When the district court denies a habeas petition on procedural grounds without
reaching the pr isoner's underlying constitutional claim , a COA should issue when the
prisoner shows , at least, that jurists of reason would find it debatable whether the petition
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states a valid claim of the denial of a constitutional right and that jurists of reason would find
it debatable whether the district court was correct in its procedural ruling. 11
Slack v.
McDaniel , 529 U.S. 473, 484 (2000). 	Logue failed to demonstrate that a certificate of
appealability should issue.
V. 	Conclusion
For the reasons set forth above, the petition for writ of habeas corpus (Doc. 1) will be
dismissed without prejudice, and a certificate of appealability will not issue . A separate
Order shall issue.
obert D. Mariani
United States District Judge
Dated : February ~ 	, 2026
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