State of Tenn. v. Thomas Patterson, 17-5187

Tennessee police seized Patterson’s truck after he allegedly drove a friend to a drug deal; state civil forfeiture proceedings were pending in state court.
Patterson filed a federal suit in the Middle District of Tennessee challenging the seizure as unconstitutional.
The seizure and most witnesses, defendants, and Patterson were located in the Eastern District; Patterson’s chosen counsel, Herbert Moncier, was suspended in the Eastern District and not eligible to practice there.
The Middle District gave Patterson two weeks to justify keeping the case; he did not, and the court transferred the case to the Eastern District.
The Eastern District denied Moncier pro hac vice admission, finding he had an avenue for reinstatement he did not pursue, then dismissed Patterson’s federal suit under Younger abstention because the state forfeiture proceeding remained ongoing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether transfer to Eastern District was improper	Patterson argued the Eastern District was an inconvenient forum	Defendants argued transfer appropriate because seizure and parties were there	Waived on appeal; Patterson didn’t preserve the objection below, so court did not reach merits
Whether denial of Moncier pro hac vice deprived Patterson of counsel	Patterson argued refusal denied his right to counsel	Defendants argued no constitutional right to counsel in civil forfeiture	No constitutional violation; no right to appointed counsel in civil cases absent detention risk
Whether federal court should abstain under Younger and dismiss suit	Patterson argued federal court should decide his constitutional claims now	Defendants argued Younger required abstention because state forfeiture pending and Tennessee has important interest	Dismissal affirmed: Younger abstention applies where state proceeding is ongoing, implicates important state interests, and provides adequate opportunity to raise constitutional claims
Whether alleged bad-faith enforcement defeats Younger abstention	Patterson alleged state seizes property and delays hearings to extort payments	Defendants denied bad faith; pointed to legitimate law enforcement interest	Allegations insufficiently specific; no evidence of harassment or bad-faith prosecution, so Younger still applies

Younger v. Harris, 401 U.S. 37 (1971) (federal courts must abstain where parallel state proceedings implicate important state interests)
Middlesex Cty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423 (1982) (Younger abstention framework)
Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69 (2013) (civil enforcement proceedings fall within Younger)
Turner v. Rogers, 564 U.S. 431 (2011) (no general constitutional right to counsel in civil cases except where liberty is at stake)
Loch v. Watkins, 337 F.3d 574 (6th Cir. 2003) (recognizing state interest in forfeiture enforcement and Younger application)
In re Moncier, 550 F. Supp. 2d 768 (E.D. Tenn. 2008) (background on Moncier’s suspension from practice)