Echols v. Johnson County Jail

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
CLIFTON ECHOLS, §
#201901362, §
PETITIONER, §
§
V. § CIVIL CASE NO. 3:25-CV-3419-G-BK
§
JOHNSON COUNTY JAIL, §
RESPONDENT. §
FINDINGS, CONCLUSIONS AND RECOMMENDATION
OF THE UNITED STATES MAGISTRATE JUDGE
Pursuant to 28 U.S.C. § 636(b) and Special Order 3, Petitioner Clifton Echols’ pro se
petition for writ of habeas corpus under 28 U.S.C. § 2241 was referred to the United States
magistrate judge for case management, including the issuance of findings and a recommended
disposition where appropriate. The Court granted Echols’ motion to proceed in forma pauperis
but did not order a response pending judicial screening. Doc. 5. As detailed here, the petition
should be summarily DISMISSED WITHOUT PREJUDICE pursuant to the Younger
abstention doctrine.
I. BACKGROUND
Echols, a Johnson County Jail pretrial detainee, challenges his pending criminal charges
and habitual offender enhancements. Doc. 3. He is awaiting trial on an indictment charging him
with tampering or fabricating physical evidence with intent to impair and possession of a
controlled substance. Doc. 3 at 2-3; State v. Echols, Nos. DC-F202500906 (18th Dist. Court,
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Johnson Cnty., Tex.).1 Doc. 3 at 3. Echols asserts that (1) the “facts do not match the
indictment” and there is an overall “lack of evidence,” (2) he is an innocent bystander who was
improperly charged with tampering with the evidence, and (3) the enhancements are erroneous.
Doc. 3 at 5-6. Echols requests that the “bogus case be dismissed.” Doc. 3 at 7. He also
indicates that he is represented in the state court by court-appointed counsel. Doc. 3 at 8.
II. ANALYSIS
Challenges raised in a pretrial habeas corpus petition are governed by 28 U.S.C. § 2241.
See Stringer v. Williams, 161 F.3d 259, 262 (5th Cir. 1998). A § 2241 habeas petition is subject
to summary dismissal if it appears from the face of the petition that the petitioner is not entitled
to relief. See Wottlin v. Fleming, 136 F.3d 1032, 1034 (5th Cir. 1998) (affirming summary
dismissal of § 2241 petition without ordering an answer from respondent); see also Rule 4 of the
RULES GOVERNING SECTION 2254 CASES (providing for summary dismissal of habeas petitions).2
Review of pretrial habeas petitions is limited, however, to avoid unwarranted interference
with ongoing state-court criminal proceedings. Kolski v. Watkins, 544 F.2d 762, 766 (5th Cir.
1977) (applying Younger abstention doctrine to pretrial habeas petition, noting “no practical
difference between granting federal habeas relief from a pending state criminal trial and
enjoining the same trial”). Thus, the Court must first examine the threshold question of whether
it has subject matter jurisdiction.
1 The trial court docket sheet is available on the Johnson County website by selecting “criminal
records” at https://pa.johnsoncountytx.org/PublicAccess/default.aspx and then entering the
criminal case numbers (last accessed Dec. 18, 2025).
2 Rule 1(b) of the RULES GOVERNING SECTION 2254 CASES renders the 2254 Rules applicable to
habeas petitions not covered by § 2254.
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Echols raises constitutional challenges related to his ongoing state criminal case. The
Younger abstention doctrine precludes federal courts from granting injunctive or habeas relief
based on constitutional challenges to state criminal prosecutions that are pending at the time the
federal action is instituted. Younger v. Harris, 401 U.S. 37, 41 (1971); Kolski, 544 F.2d at 766.
For Younger to apply, three criteria must be satisfied: (1) the dispute must involve an ongoing
state judicial proceeding; (2) an important state interest in the subject matter of the proceeding
must be implicated; and (3) the state proceeding must afford an adequate opportunity to raise
constitutional challenges. Gates v. Strain, 885 F.3d 874, 880 (5th Cir. 2018) (citations omitted).
The Younger abstention requirements are met here. First, Echols asks the Court to
intervene and dismiss his pending state criminal case, and this Court’s grant of habeas relief
would necessarily interfere with the state court’s ability to conduct its own proceedings, in
contravention of Younger. See Bice v. La. Pub. Def. Bd., 677 F.3d 712, 716 (5th Cir. 2012)
(“Interference is established ‘whenever the requested relief would interfere with the state court’s
ability to conduct proceedings, regardless of whether the relief targets the conduct of a
proceeding directly.’”). Further, the state obviously has a vital interest in prosecuting violations
of its criminal laws. DeSpain v. Johnston, 731 F.2d 1171, 1176 (5th Cir. 1984) (“The state has a
strong interest in enforcing its criminal laws.”). Also, Echols can litigate the claims he raises
here in the state proceedings where he is represented by appointed counsel. Texas courts also
offer Echols the chance to exhaust any claim of ineffective assistance of counsel on collateral
review if he is convicted. See Trevino v. Thaler, 569 U.S. 413, 426 (2013).
Finally, Echols has not suggested, much less shown, that the very narrow exceptions to
the Younger abstention doctrine apply here. See Gates, 885 F.3d at 881 (detailing exceptions and
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noting the petitioner bears the burden of proof (citing Younger, 401 U.S. at 45)). As relevant
here, Echols’ dissatisfaction with the criminal proceedings does not rise to extraordinary
circumstances. Kugler v. Helfant, 421 U.S. 117, 124 (1975) (“Only if ‘extraordinary
circumstances’ render the state court incapable of fairly and fully adjudicating the federal issues
before it, can there be any relaxation of the deference accorded to the state criminal process.”);
Chavez v. Dallas Cnty. Sheriff’s Off., No. 3:21-CV-891-B-BK, 2022 WL 2182189, at *3 (N.D.
Tex. Apr. 21, 2022), rec. adopted, 2022 WL 2181067 (N.D. Tex. June 16, 2022) (dismissing pre-
trial habeas petition raising ineffective assistance of counsel, among other grounds, based on the
Younger abstention doctrine because the petitioner had shown no extraordinary circumstances).
In sum, because Echols cannot show that any exception to the Younger abstention
doctrine is warranted, the Court should abstain from exercising habeas jurisdiction over his
claims that seek federal intervention in his pending Johnson County prosecution. See Kolski, 544
F.2d at 766 (affirming denial of federal habeas petition by state pretrial detainee relating to his
pending criminal prosecution).
III. CONCLUSION
For all these reasons, the habeas corpus petition should be DISMISSED WITHOUT
PREJUDICE under the Younger abstention doctrine.
SO RECOMMENDED on December 22, 2025.
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INSTRUCTIONS FOR SERVICE AND
NOTICE OF RIGHT TO APPEAL/OBJECT
A copy of this report and recommendation will be served on all parties in the manner provided by
law. Any party who objects to any part of this report and recommendation must file specific
written objections within 14 days after being served with a copy. See 28 U.S.C. § 636(b)(1); FED.
R. CIV. P. 72(b). An objection must identify the finding or recommendation to which objection is
made, the basis for the objection, and the place in the magistrate judge’s report and
recommendation the disputed determination is found. An objection that merely incorporates by
reference or refers to the briefing before the magistrate judge is not specific. Failure to file specific
written objections will bar the aggrieved party from appealing the factual findings and legal
conclusions of the magistrate judge that are accepted or adopted by the district court, except upon
grounds of plain error. See Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1417 (5th Cir.
1996), modified by statute on other grounds, 28 U.S.C. § 636(b)(1) (extending the time to object
to 14 days).
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