Soraya Maria Rigor v. Sacramento Regional Transit, et al.

Summary

A magistrate judge recommends dismissal without further leave to amend of Soraya Maria Rigor’s pro se action against Sacramento Regional Transit and other defendants. The recommendations conclude that the claims challenging a 2008 conviction are barred by Heck v. Humphrey, that any claims not barred by Heck are untimely, and that the complaint otherwise fails to state a claim under 42 U.S.C. § 1983.

Holdings

1. A § 1983 damages action that would necessarily imply the invalidity of an underlying conviction is barred unless the conviction has been invalidated on appeal, expunged, vacated, or otherwise called into question through an appropriate proceeding.
2. Claims under 42 U.S.C. § 1983 arising from the alleged 2008 arrest, conviction, or confinement were untimely because California's two-year personal-injury limitations period applied and Plaintiff did not file until 2025.
3. The complaint failed to state a claim under § 1983 because it did not clearly allege a constitutional violation, did not establish a viable claim under the identified amendments, and could not rely on 18 U.S.C. § 242 as a private civil cause of action.
4. Further leave to amend should be denied because Plaintiff had already been given an opportunity to amend, failed to do so, and her response confirmed incurable Heck and statute-of-limitations defects.

Questions Presented

1. Whether Plaintiff's 42 U.S.C. § 1983 claims challenging the validity of her 2008 conviction are barred by Heck v. Humphrey.
2. Whether claims arising from the 2008 arrest, conviction, or confinement are barred by the applicable two-year statute of limitations.
3. Whether the complaint states a claim under § 1983 or otherwise identifies a viable constitutional or federal statutory cause of action.
4. Whether further leave to amend should be denied as futile.

Disposition

dismissed