Watkins v. Ohio Dep't of Educ.
| Docket Number | 2:21-cv-04482 |
| Decision Date | 07 March 2022 |
| Parties | STANLEY WATKINS, Plaintiff, v. OHIO DEPARTMENT OF EDUCATION, et al. Defendants. |
| Court | U.S. District Court — Southern District of Ohio |
DEAVERS MAGISTRATE JUDGE
This matter is before the Court on Plaintiff's Motion for Preliminary Injunction. (ECF No. 16). The hearing on this Motion was held on Wednesday, February 23, 2022, at 10:00 a.m. For the reasons set forth below, the Court finds that the Younger abstention doctrine applies to this case, and, as a result this case is STAYED. Accordingly, the Court DENIES Plaintiff's Motion for Preliminary Injunction (Id.).
Plaintiff is a former special education teacher previously employed with the Columbus City Schools (“CCS”). (ECF No. 1 at 3). In 2015, the Ohio Department of Education (“ODE”) issued Plaintiff a four-year alternative license, enabling him to teach children with disabilities. (Id.). After being observed falling asleep during class, among other things, CCS terminated Plaintiff's employment. (Id. at 6). Following his termination, the ODE initiated an investigation concerning Plaintiff's license to teach. (Id. at 3).
Sometime in early 2017, Plaintiff was notified that he was being investigated by ODE. (Id.). On March 20, 2017, Plaintiff contacted ODE requesting a copy of the “complaint.” (Id.).
Plaintiff alleges that ODE refused his request noting that it was unable to disclose such information because it was confidential. (Id.). On March 26, 2018-about a year later, Plaintiff renewed his request with ODE; the state agency again refused his request on the same grounds. (Id.).
Approximately two years after notifying Plaintiff of the investigation, ODE provided Plaintiff with Notice of an Investigation Decision on January 23, 2019. (Id.). Attached to the emailed Notice was a request that Plaintiff voluntarily surrender his teaching license and agree to a permanent bar from subsequently applying. (Id. at 3-4). The same day Plaintiff received this Notice, he requested a hearing. (Id. at 4). Plaintiff then twice attempted-once in February 2019 and then in July 2019-to apply for some sort of licensure update. (Id.). Because his four-year license was set to expire on June 30, 2019, it is likely that at least one of these applications was for a renewal, although Plaintiff is unclear on this point. (See id.).
Plaintiff complains that ODE accepted his application fees yet constructively suspended his license in 2019; Plaintiff's license continues to be suspended. (See id.).
On February 6, 2019, Plaintiff filed his initial federal lawsuit arising from his termination as a special education teacher. (ECF No. 9 at 2). There, he similarly asserted a § 1983 claim alleging deprivation of his due process rights in that CCS failed to “properly notify him about his pre-disciplinary hearing.” Watkins v. Columbus City Sch., No. 2:19-CV-394, 2020 WL 1290298, at *1 (S.D. Ohio Mar. 18, 2020), aff'd, No. 20-3357, 2020 WL 9073357 (6th Cir. Nov. 10, 2020). The Court ultimately found that Watkins's claim was barred by the relevant statute of limitations. Id. at *9.
In the same suit, Plaintiff attempted to remove the now complained of ODE proceedings to federal court. See Id. Plaintiff asserted that the Southern District of Ohio had jurisdiction because the proceedings concerned a federal cause of action: a separate § 1983 claim. The Court rejected this argument because the proceedings arose “under Chapter 19, Title 33 of the Ohio Revised Code and Chapter 3301-73 of the Ohio Administrative Code, which allow the State Board of Education to suspend, revoke, or deny a teaching license.” Id. Plaintiff also asserted that because he presented a defense sounding in federal law that the proceedings were removable. Id. at *10. The Court similarly rejected this argument noting that asserting “a federal defense is not a basis for removal.” Id.
Watkins filed his Complaint (ECF No. 1) and Motion for Temporary Restraining Order (ECF No. 2) against Defendants in the case sub judice on September 10, 2021. Defendants include the State of Ohio, two state agencies, an agency board, and officials of those agencies. (ECF No. 1). The state agencies include the Ohio Department of Education (“ODE”) and the state Attorney General's Office (“AGO”). (Id.). Additionally, Plaintiff is suing the state Board of Education- a decision-making body within ODE. (Id.). Finally, officials at the state agencies include members of the Ohio Department of Education (Paola DeMaria, former Superintendent of Public Instruction; Laura Kohler, President; Liza Dietrich, Staff Attorney; Samuel Dunsky, Staff Attorney; and Aaron Ross, former Managing Attorney at the Office of Professional Conduct) (“ODE Defendants” or “ODE”) and the Attorney General's Office (Dave Yost, Ohio Attorney General; Zoe Saadey, Associate Attorney General; and Ashley Barbone, Associate Attorney General) (“AGO Defendants” or “AGO”). (Id.).
On September 14, 2021, the Court denied Plaintiff's Motion for Temporary Restraining Order. (ECF No. 11). Plaintiff filed his Motion for Preliminary Injunction on October 4, 2021. (ECF No. 16). In his motion for Preliminary Injunction, Plaintiff, in tandem with the complaint, seeks an injunction to reinstate his teaching license while the Court considers the constitutionality of the state administrative proceedings. (Id.). Moreover, Plaintiff also requests that the Preliminary Injunction hearing be consolidated with a trial on the merits pursuant to Fed.R.Civ.P. 65(a)(2). (Id.). ODE Defendants and AGO Defendants each filed their Response in Opposition on October 12, 2021. (ECF Nos. 17, 18). On October 15, 2021, Plaintiff requested to appear telephonically at the hearing or, in the alternative, to continue the hearing until February 2022. (ECF No. 20). The Court granted Plaintiff's Motion to Continue and ordered Plaintiff to file a Reply brief addressing Younger abstention. (ECF No. 22). Plaintiff filed his Reply on January 24, 2022. (ECF No. 25).
At the Preliminary Injunction hearing, Plaintiff withdrew his request to consolidate the hearing with the trial on the merits. The Court heard argument, primarily on Younger abstention. No. testimony nor exhibits were entered into evidence. This motion is ripe for adjudication.
The “purpose of a preliminary injunction is merely to preserve the relative positions of the parties until a trial on the merits can be held.” Univ. of Tex. v. Camenisch, 451 U.S. 390, 395 (1981). In light of its “limited purpose, ” a preliminary injunction is “customarily granted on the basis of procedures that are less formal and evidence that is less complete than in a trial on the merits.” Certified Restoration Dry Cleaning Network, L.L.C. v. Tenke Corp., 511 F.3d 535, 542 (6th Cir. 2007). Accordingly, a party need not prove her case in full at a preliminary injunction hearing. Id. But see Leary v. Daeschner, 228 F.3d 729, 739 (6th Cir. 2000) ().
When considering a motion for preliminary injunction, a district court must balance four factors: (1) whether the movant has a strong likelihood of success on the merits; (2) whether the movant would suffer irreparable injury without the injunction; (3) whether issuance of the injunction would cause substantial harm to others; and (4) whether the public interest would be served by the issuance of the injunction. Ne. Ohio Coal. for the Homeless v. Husted, 696 F.3d 580, 590-91 (6th Cir. 2012). These four considerations are “factors to be balanced, not prerequisites that must be met.” Certified Restoration, 511 F.3d at 542. Whether the combination of the factors weighs in favor of issuing injunctive relief in a particular case is left to the discretion of the district court. See Leary, 228 F.3d at 739.
Yet, “[w]hen faced with a threshold question of whether to apply the Younger abstention doctrine, a court must first address the Younger issue prior to engaging in any analysis on the merits of the case.” Kalniz v. Ohio State Dental Bd., 699 F.Supp.2d 966, 970 (S.D. Ohio 2010) (Marbley, J.) (); see also Lighthouse Cmty. Church of God v. City of Southfield, 382 F.Supp.2d 937, 939 (E.D. Mich. 2005); Doe v. Lee, No. 3:20-CV-00610, 2020 WL 4926607, at *2 (M.D. Tenn. Aug. 21, 2020). Although “federal courts are not required to abstain once they have undertaken “proceedings of substance on the merits, ” this conclusion is not supported when federal court proceedings have not progressed passed the “embryonic stage.” See Cremeans v. Taczak, No. 2:19-CV-2703, 2019 WL 5420256, at *7 (S.D. Ohio Oct. 23, 2019) (Marbley, J.) (internal quotations omitted).
Abstention is a judicially created doctrine that precludes federal courts from deciding some matters before them, even if other jurisdictional and justiciability requirements are met. Indeed, abstention doctrines exist “to promote harmony between the state and federal courts” and to reflect the “belief that the state courts should be left to decide matters of unique importance to them.” Summit Cty. Crisis Pregnancy Ctr., Inc. v. Fisher, 830 F.Supp. 1029, 1032 (N.D. Ohio 1993). One variety of abstention doctrine, Younger, “cautions federal courts against exercising jurisdiction in cases where they are asked to enjoin pending state proceedings.” Fowler v. Benson, 924 F.3d 247, 255 (6th Cir. 2019) (citing New Orleans Pub. Serv., Inc. v. Council of...
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