John Patrick Smylie v. Plumas County District Attorney's Office, et al.

Summary

The United States District Court for the Eastern District of California granted John Patrick Smylie’s application to proceed in forma pauperis and assessed the statutory filing fee. The court screened his 42 U.S.C. § 1983 complaint and dismissed it with leave to amend, concluding that the claims against the prosecutor were barred by absolute prosecutorial immunity and that the claims against the Plumas County District Attorney’s Office lacked sufficient allegations. The court ordered plaintiff to file an amended complaint within thirty days.

Holdings

1. A prosecutor is absolutely immune from § 1983 damages liability for conduct related to plea bargaining because plea bargaining is intimately associated with the judicial phase of the criminal process.
2. A prosecutor is absolutely immune from § 1983 damages liability for false or defamatory statements made during judicial proceedings and for presenting the state's case during the judicial phase of a criminal prosecution.
3. The excessive-sentence allegation failed to state a claim because plaintiff did not connect any defendant to the alleged constitutional deprivation; moreover, a claim for damages against the sentencing judge based on the judicial act of sentencing would be barred by judicial immunity.
4. The claims against the Plumas County District Attorney's Office were inadequately pleaded because the complaint contained no allegations against the office and did not identify a municipal policy or custom that caused a constitutional violation.

Questions Presented

1. Whether the complaint stated a cognizable § 1983 damages claim based on the prosecutor's plea-bargaining conduct.
2. Whether the prosecutor was absolutely immune from damages liability for allegedly false, defamatory, or other statements made during judicial criminal proceedings.
3. Whether the excessive-sentence allegation stated a claim when no defendant was linked to it and any claim against the sentencing judge would concern a judicial act.
4. Whether the complaint adequately alleged municipal or organizational liability against the Plumas County District Attorney's Office.

Disposition

dismissed