Jones v. Smalling, et al.

Summary

The United States District Court for the Eastern District of California grants Kevin Lawrence Jones’s application to proceed in forma pauperis in his 42 U.S.C. § 1983 action. The court recommends dismissal without prejudice under Heck v. Humphrey because the claims challenging his criminal proceedings would imply the invalidity of his conviction or confinement. The matter is referred to a district judge, and the parties are given fourteen days to file objections.

Holdings

1. A state prisoner's § 1983 claims are not cognizable when success would necessarily imply the invalidity of the prisoner's confinement unless the conviction or sentence has already been invalidated. Because plaintiff's allegations challenged the fairness and validity of his criminal trials, the complaint was subject to dismissal without prejudice, with habeas corpus identified as the proper vehicle for the challenge.
2. A prisoner complaint proceeding in forma pauperis must be dismissed at screening if it is frivolous, malicious, fails to state a claim, or seeks monetary relief from an immune defendant; a pro se complaint must also satisfy Rule 8 and contain sufficient factual matter to state a facially plausible claim.

Questions Presented

1. Whether the prisoner's § 1983 claims challenging the fairness and validity of his criminal trials are cognizable before the underlying convictions or sentences have been invalidated.
2. Whether the complaint satisfies the screening and pleading requirements applicable to a prisoner proceeding in forma pauperis.

Disposition

dismissed