Evans v. Shea
CourtDistrict Court, District of Columbia
Date FiledOctober 28, 2026
DocketCivil Action No. 2026-2403
JudgeJudge Trevor N. McFadden
StatusPublished
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Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JOSEPH M. EVANS, )
)
Plaintiff, )
)
v. ) Civil Action No. 1:26-cv-02403 (UNA)
)
)
TIMOTHY J. SHEA, et al., )
)
Defendants. )
MEMORANDUM OPINION
This matter is before the court on plaintiff’s application for leave to proceed in forma
pauperis (“IFP”), ECF No. 2, and pro se civil complaint, ECF No. 1. Plaintiff’s IFP application
is granted and, for the reasons discussed below, this case is dismissed without prejudice.
Plaintiff is currently civilly committed while awaiting a finding that he is competent to
stand trial, as he is facing felony charges brought against him in the Superior Court of the District
of Columbia. See United States v. Evans, No. 2020 CF1 001935 (D.C. Super. Ct. filed 2/12/2020).1
In the instant matter, he declares his innocence, states that he is indeed competent to stand trial,
alleges that he has been improperly detained, and he challenges the validity of the evidence giving
rise to his charges.
As a general rule, applicable here, this court lacks jurisdiction to interfere with the
proceedings or review decisions made by the D.C. Superior Court. See Fleming v. United States,
847 F. Supp. 170, 172 (D.D.C. 1994) (relying on District of Columbia Court of Appeals v.
Feldman, 460 U.S. 462, 482 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413, 415, 416
(1923)).
1
A court may take judicial notice of the docket and facts on the public record in other judicial
proceedings. See Covad Commc’ns Co. v. Bell Atl. Corp., 407 F.3d 1220, 1222 (D.C. Cir. 2005).
To that same end, this court cannot hear claims or issues related to ongoing state criminal
proceedings, given “the fundamental policy against federal interference with state criminal
prosecutions.” Younger v. Harris, 401 U.S. 37, 46. (1971); see Dist. Prop. Assoc. v. Dist. of
Columbia, 743 F.2d 21, 27 (D.C. Cir. 1984) (“[B]ased on principles of equity . . . the doctrine of
Younger v. Harris, 401 U.S. 37 (1971), and its progeny restrains federal courts from interfering in
ongoing state judicial proceedings.”); see also 28 U.S.C. § 2244(d)(1)(a), (d)(2).
Accordingly, the court dismisses the complaint, ECF No. 1, and this matter, without
prejudice. A separate order accompanies this memorandum opinion.
TREVOR N. McFADDEN
Date: October 28, 2026 United States District Judge