Albert John Hamilton v. Department of Corrections

Summary

The United States District Court for the Eastern District of California dismissed Albert John Hamilton’s § 1983 complaint with leave to amend. The court held that claims for damages against the California Department of Corrections and Rehabilitation were barred by the Eleventh Amendment and that a parole-board officer would likely have absolute quasi-judicial immunity. The court directed plaintiff to file a complete amended complaint within thirty days and to address the statute of limitations.

Holdings

1. The claims were not barred by Heck because habeas relief concerning the 2003 parole revocation was no longer available, bringing the claims within the limited Nonnette v. Small exception.
2. The claims for damages against CDCR were barred by the Eleventh Amendment because CDCR is a state agency and no waiver or valid congressional abrogation was shown.
3. To the extent plaintiff intended to sue parole-board officer J. Bock for revoking parole, Bock appeared entitled to absolute quasi-judicial immunity because parole revocation is a quasi-judicial function.
4. Any amended complaint must allege how each defendant's conduct caused a constitutional deprivation and must contain specific, nonconclusory allegations; the amended complaint must also be complete in itself.

Questions Presented

1. Whether the claims challenging the 2003 parole revocation were barred by Heck v. Humphrey's favorable-termination rule.
2. Whether damages claims under 42 U.S.C. § 1983 against CDCR were barred by Eleventh Amendment immunity.
3. Whether a parole-board official would be entitled to absolute quasi-judicial immunity for revoking parole.
4. Whether the complaint stated a constitutionally sufficient claim and complied with federal pleading requirements.

Disposition

remanded