Habib, Marwan v. Miami Dade District Attorney, 1:24-cv-20865

Marwan Habib, a pretrial detainee, filed a habeas corpus petition under 28 U.S.C. § 2241 challenging his ongoing state court criminal prosecution in Miami-Dade County, Florida.
The district court dismissed Habib’s petition on the grounds that it was barred by the Younger abstention doctrine, which generally prohibits federal courts from interfering with ongoing state criminal proceedings.
Habib, acting pro se, subsequently filed a motion for reconsideration under Federal Rule of Civil Procedure 60(b), arguing new grounds for federal intervention.
The motion for reconsideration raised allegations of bad faith by the prosecution and trial judge, claimed irreparable injury due to alleged physical abuse in jail, and challenged the constitutionality of the statute under which he was prosecuted.
The court evaluated whether Habib's arguments satisfied any of the limited exceptions to the Younger abstention doctrine or entitle him to relief under Rule 60(b).
The court also addressed whether claims regarding conditions of confinement were properly raised in a habeas petition or should be addressed under 42 U.S.C. § 1983.

Issue	Habib’s Argument	State/Respondent’s Argument	Held
Applicability of Younger abstention exceptions	Exceptions apply due to bad faith and injury	No sufficient evidence for exceptions	Exceptions not established; Younger abstention applies
Bad faith of prosecution/judiciary	Prosecutor and judge motivated by politics and bad faith	Allegation is conclusory and unsupported	No evidence of bad faith; allegation insufficient
Irreparable injury	Physical abuse in jail as irreparable injury affecting his career	Physical abuse claims not cognizable under § 2241	Physical injury claim must be brought under § 1983, not habeas; does not meet exception
State court as adequate forum	Claims state court is not considering his arguments	He can seek state remedies (writ of mandamus, etc.)	State forum available; failure or delay resolvable by mandamus, not habeas petition

Younger v. Harris, 401 U.S. 37 (1971) (sets out abstention rules for ongoing state criminal proceedings and the narrow exceptions)
Hudson v. Hubbard, [citation="358 F. App'x 116"] (11th Cir. 2009) (explains requirement of substantial showing of bad faith for Younger exception)
Nelson v. Campbell, 541 U.S. 637 (2004) (conditions of confinement claims must be brought under § 1983, not habeas)
Butler v. Ala. Jud. Inquiry Comm’n, 245 F.3d 1257 (11th Cir. 2001) (circumstances justifying Younger exceptions)