Alexandre Zdenek Davis II v. The State of Idaho, The Ada County Public Defenders Office, Ada County Sheriff Department

Summary

The United States District Court for the District of Idaho screened Alexandre Zdenek Davis II’s pro se prisoner civil rights complaint concerning pending Idaho criminal charges, an outstanding warrant, and alleged speedy-trial violations. The court concluded that the speedy-trial issues must be pursued in state court through appointed counsel and that the State of Idaho is protected from the asserted federal claims by sovereign immunity and other jurisdictional limits. The case was dismissed without prejudice, and the plaintiff’s pending motions were denied or granted as moot.

Holdings

1. The speedy-trial question concerning Plaintiff's pending Idaho criminal case must be determined in the Idaho state district court, and Plaintiff must follow that court's procedures for represented litigants and requests to proceed pro se.
2. The State of Idaho and its state entities are immune from Plaintiff's § 1983 suit in federal court because Idaho has not waived its sovereign immunity and Congress has not validly abrogated it for such suits; the State also is not a person subject to suit under § 1983.
3. The federal district court lacks jurisdiction to issue a writ of mandamus requiring a state court to take action.

Questions Presented

1. Whether Plaintiff's federal civil-rights action could provide relief concerning the alleged delay in his pending Idaho criminal prosecution and speedy-trial claim.
2. Whether the State of Idaho was subject to suit under 42 U.S.C. § 1983 in federal court.
3. Whether the federal district court had jurisdiction to issue mandamus relief directing a state court to act.
4. Whether the action should be dismissed without prejudice at the PLRA screening stage.

Disposition

dismissed