Summary
The United States District Court for the Central District of Illinois screened Andrew Wright’s amended 42 U.S.C. § 1983 complaint concerning alleged unlawful searches, seizures, property damage, and fabricated criminal charges. The court dismissed the complaint without prejudice under Heck v. Humphrey and granted Wright 30 days to file a second amended complaint.
Topics
Practice areas
Questions Presented
- Whether the amended § 1983 complaint could proceed when success on the alleged unlawful arrest, searches, seizures, and evidence-fabrication claims would imply the invalidity of an outstanding criminal conviction or sentence.
- Whether the City of Beardstown could be held liable under § 1983 solely for the alleged actions of its employees.
Holdings
- A plaintiff may not pursue damages under § 1983 when success would imply the invalidity of a criminal conviction or sentence unless that conviction or sentence has been invalidated. Because Wright did not show that any conviction had been invalidated, his amended complaint was barred by Heck v. Humphrey and was dismissed without prejudice.
- A municipality and its officials are not vicariously liable under § 1983 for the conduct of subordinates; officials are accountable for their own acts.
Key quotations
“Plaintiff may not pursue a § 1983 claim for damages, the success of which would imply the invalidity of a criminal conviction or sentence, unless that conviction or sentence has been invalidated.”
“There is no respondeat superior under § 1983. Officials are accountable for their own acts; they are not vicariously liable for the conduct of subordinates.”
Factual background
Wright alleged that Beardstown police damaged doors and took property while entering his residence, conducted additional warrantless searches, and left doors open. He further alleged that Officer Ian Dennis arrested him, searched and seized his iPhones, and searched bags and a garage without warrants. Wright also alleged that Police Chief Martin Coad tampered with evidence and falsified information to support criminal charges. The court noted that Wright did not identify the status of the related criminal case or show that any conviction had been invalidated.
Procedural history
Wright filed an amended complaint alleging constitutional violations arising from searches, seizures, an arrest, alleged evidence tampering, and false criminal charges. The court screened the amended complaint under 28 U.S.C. § 1915A and dismissed it without prejudice under Heck v. Humphrey because the allegations necessarily challenged the validity of Wright's arrest, incarceration, or criminal case and Wright had not shown that any conviction had been invalidated. The court granted Wright a final opportunity to file a second amended complaint within 30 days.