Shane Gates v. Rodney Strain, 885 F.3d 874

In 2006 Shane Gates was stopped, arrested, and charged with multiple offenses (including DWI and resisting an officer); he filed a § 1983 suit in 2007 alleging excessive force and bad-faith prosecution and seeking damages and an injunction halting state prosecution.
The federal action was stayed in 2008 pending resolution of the underlying state criminal proceedings; Gates was later acquitted of aggravated flight in 2012, but misdemeanor charges (DWI, resisting) remained pending.
Gates failed to appear for the misdemeanor trials beginning in 2013; an attachment issued for his arrest and his whereabouts have been unknown to counsel since then.
Defendants asked the district court to lift the federal stay to permit service for the misdemeanor trial and, if Gates failed to appear, to dismiss his § 1983 case for failure to prosecute; Gates moved to lift the stay to obtain an injunction preventing the state prosecutions.
The district court found Younger abstention barred injunctive relief and, because Gates’ flight and failure to prosecute had prevented resolution of the state cases, dismissed his § 1983 suit with prejudice under Fed. R. Civ. P. 41(b); the Fifth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal court may enjoin pending state criminal prosecutions	Gates: federal court should enjoin state misdemeanor prosecutions (bad faith, double jeopardy, speedy-trial violation)	Defs: Younger abstention bars injunction; state has important interest and plaintiff can raise claims in state court	Younger applies; injunction denied
Whether prosecution was in bad faith to trigger Younger exception	Gates: prosecution instigated by insurer/DA relationship and forged evidence — shows bad faith	Defs: prosecution had legitimate basis (resisting was supported by report); no proof of intent to prosecute without hope of conviction	No bad faith found; exception not met
Whether double jeopardy bars the pending misdemeanor prosecutions	Gates: acquittal on aggravated flight precludes relitigation of overlapping evidence	Defs: prior acquittal did not resolve ultimate facts for DWI/resisting; different elements	Double-jeopardy not shown; exception not met
Whether dismissal with prejudice for failure to prosecute was appropriate	Gates: delay attributable to district-court stay, not his conduct	Defs: stay was prolonged because Gates failed to appear for state proceedings; his flight prevented resolution	Dismissal with prejudice affirmed: clear record of delay by Gates, warnings given, lesser sanctions inadequate

Mitchum v. Foster, 407 U.S. 225 (1972) (§ 1983 authorizes federal injunctions against state proceedings but equitable/comity limits apply)
Younger v. Harris, 401 U.S. 37 (1971) (federal courts should generally abstain from interfering with ongoing state criminal proceedings)
Middlesex Cty. Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (1982) (articulates the three-part Younger test: ongoing proceeding, important state interest, opportunity to raise federal claims in state court)
Dowling v. United States, 493 U.S. 342 (1990) (clarifies that collateral estoppel/double jeopardy applies only where prior acquittal decided an ultimate issue in the later case)
Heck v. Humphrey, 512 U.S. 477 (1994) (limits § 1983 claims that would imply the invalidity of pending or unresolved criminal convictions; courts often stay civil claims until criminal cases conclude)
Link v. Wabash R.R. Co., 370 U.S. 626 (1962) (courts have inherent power to dismiss cases for failure to prosecute)