David Lange v. Hennepin County, Minnesota, et al.

Summary

The United States District Court for the Eastern District of Arkansas grants David Lange’s application to proceed in forma pauperis but dismisses his complaint without prejudice. The court holds that Lange’s § 1983 claims are barred by Heck v. Humphrey, his RICO and § 1985(3) claims are inadequately pleaded, and it declines supplemental jurisdiction over his state-law claims. The court also denies two motions seeking preliminary injunctive and emergency relief.

Holdings

1. Claims under § 1983 that necessarily imply the invalidity of Lange's state conviction, continued imprisonment, or sentence are not cognizable unless the conviction or sentence has been reversed, expunged, invalidated, or called into question by federal habeas relief. Lange's malicious-prosecution, fabrication-of-evidence, retaliatory-prosecution, and conscience-shocking-abuse-of-process claims were therefore barred.
2. The federal district court lacked jurisdiction under § 1983 to modify a state-court order, dismiss a state-court warrant, or expunge state criminal records; habeas corpus is the federal remedy for attacking the validity of a conviction or confinement.
3. Lange failed to state a RICO claim because he did not plead with the required specificity an enterprise or coordinated conduct among the defendants, including the required who, what, when, where, and how of the alleged racketeering conduct.
4. Lange failed to state a claim under § 1985(3) because he did not plead particularized facts showing an agreement or meeting of the minds directed toward unconstitutional action, and his conclusory allegations of class-based racial animus were insufficient.
5. The court declined to exercise supplemental jurisdiction over Lange's state-law claims after dismissing all federal claims.
6. Both motions for preliminary injunction and related emergency relief were denied because Lange failed to state a viable federal claim and therefore could not establish a likelihood of success on the merits.

Questions Presented

1. Whether Lange's claims under 42 U.S.C. § 1983 were barred by Heck v. Humphrey because success would imply the invalidity of his state conviction, imprisonment, or sentence.
2. Whether the court had jurisdiction under § 1983 to expunge criminal records or modify or dismiss a state-court warrant or conviction.
3. Whether Lange adequately pleaded a RICO enterprise and pattern of racketeering activity under 18 U.S.C. § 1962 and Federal Rule of Civil Procedure 9(b).
4. Whether Lange adequately pleaded a class-based, invidiously discriminatory conspiracy and agreement under 42 U.S.C. § 1985(3).
5. Whether the court should exercise supplemental jurisdiction over the state-law claims and grant preliminary injunctive or emergency relief.

Disposition

dismissed