Lawrence L. Ingram v. Doyet A. Early, III, J. Christopher Wilson, Warden Willie Davis, Courtney Bennett, Officer Adkinson, Department of Probation, United States of America

Summary

The United States District Court for the District of South Carolina adopted a magistrate judge’s recommendation and dismissed Lawrence L. Ingram’s pro se action without prejudice, without leave to amend, and without issuance and service of process. The court concluded that the complaint failed to state a federal claim, that certain claims were barred by Heck v. Humphrey, and that other claims were barred by judicial immunity, lack of state action, or official-capacity limitations. The court declined supplemental jurisdiction over any state-law claims and denied the plaintiff’s motion for default and default judgment as moot.

Holdings

1. Because Plaintiff did not make specific objections to any portion of the Report, the district court was required to review the recommendation for clear error rather than conduct de novo review of the entire Report.
2. The amended complaint failed to state a federal claim upon which relief could be granted because it did not provide specific facts showing that any named defendant violated Plaintiff's federal constitutional or statutory rights.
3. Plaintiff's claims for monetary damages relating to his kidnapping and carjacking convictions and sentences were barred by Heck v. Humphrey.
4. Judge Doyet A. Early, III was entitled to judicial immunity because the claims against him arose from judicial actions.
5. J. Christopher Wilson could not be liable under any § 1983 claim gleaned from the amended complaint because he was not a state actor, and the defendants sued in their official capacities were not persons subject to liability under § 1983.
6. After dismissing the federal claims and finding no diversity jurisdiction, the court declined to exercise supplemental jurisdiction over any state-law claims Plaintiff may have attempted to assert.
7. Plaintiff's motion for entry of default and default judgment was denied as moot.

Questions Presented

1. Whether Plaintiff's nonspecific objections required de novo review of the magistrate judge's Report and Recommendation.
2. Whether the amended complaint stated a federal constitutional or statutory claim upon which relief could be granted.
3. Whether claims for damages related to Plaintiff's convictions and sentences were barred by Heck v. Humphrey.
4. Whether judicial immunity, lack of state action, and the absence of § 1983 personhood for official-capacity defendants independently required dismissal.
5. Whether the court should exercise supplemental jurisdiction over any state-law claims after dismissal of the federal claims.
6. Whether Plaintiff's motion for entry of default and default judgment should be granted.

Disposition

dismissed