Walter Flores v. Michael T. Wood, et al.

Summary

The United States District Court for the District of New Mexico granted Sheriff Michael T. Wood’s motion to dismiss Walter Flores’s amended 42 U.S.C. § 1983 complaint. The court held that Flores’s failure-to-train allegations were conclusory and insufficient to state a municipal-liability claim, and further concluded that his claims concerning an allegedly unlawful search and fabricated evidence were barred by Heck v. Humphrey. The claims were dismissed without prejudice, and the court directed entry of final judgment.

Holdings

1. Because an amended complaint supersedes the original complaint and Flores omitted Blais from the amended pleading and alleged no facts concerning him, Blais was treated as voluntarily dismissed.
2. The amended complaint failed to state a plausible failure-to-train claim because it offered only the conclusory allegation that Sheriff Wood failed to train officers and alleged no facts showing a pattern of similar constitutional violations or that the need for additional training was obvious to municipal policymakers.
3. Heck v. Humphrey barred the claims because the alleged unlawful search and fabricated evidence claims, as pleaded, necessarily called into question the validity of Flores's still-valid convictions.

Questions Presented

1. Whether the amended complaint stated a plausible official-capacity failure-to-train claim under 42 U.S.C. § 1983.
2. Whether Heck v. Humphrey barred Flores's claims because finding that the search was unlawful or that evidence was fabricated would necessarily imply the invalidity of his still-valid criminal convictions.
3. Whether District Attorney Marcos Blais remained a defendant after Flores omitted him from the amended complaint.

Disposition

dismissed