Thomas v. Spangler, 3:24-cv-00427

Eric Thomas, a pretrial detainee at Knox County Detention Facility, filed a pro se habeas corpus petition under 28 U.S.C. § 2241, seeking release from pretrial detention due to pending charges.
Thomas alleged unconstitutional actions by state officials, including issues with presentment, evidence, trial court orders limiting communication, and thirty-three counts of violating a no-contact order.
He requested leave to proceed in forma pauperis, asserting inability to pay the filing fee.
The court granted leave to proceed in forma pauperis but addressed whether it should exercise jurisdiction over the habeas petition in light of pending state proceedings.
The court focused on whether exceptions applied allowing federal intervention in ongoing state criminal proceedings.
The court dismissed the petition without prejudice, denied a certificate of appealability, and certified that any appeal would not be taken in good faith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction over pretrial habeas petition	Federal court should intervene due to alleged constitutional violations	(Not directly stated; abstention)	Court abstained; state process adequate
Exception to abstention (Speedy trial, Double jeopardy, IAC)	Claims rise to exception for federal intervention	No exception applies	No exception shown, abstention proper
Filing fee payment	Petitioner's indigency warrants waiver		IFP granted
Certificate of appealability for denial	Substantial constitutional claim supports appeal		COA denied, no substantial showing

Atkins v. Michigan, 644 F.2d 543 (6th Cir. 1981) (federal courts should abstain from intervening in pending state criminal proceedings when state remedies are available)
Saulsberry v. Lee, 937 F.3d 644 (6th Cir. 2019) (§ 2241 is the correct vehicle for pretrial detainees seeking habeas relief)