Steven Sencial v. Arthur Coll, et al.

Summary

The United States District Court for the Eastern District of Louisiana dismissed with prejudice Steven Sencial’s 42 U.S.C. § 1983 claims against Officers Arthur Coll and A. Galvez under the Heck doctrine and for failure to state a claim. The court held that Sencial’s false-arrest, malicious-prosecution, and related claims would imply the invalidity of his guilty pleas to four counts of aggravated assault. The court declined supplemental jurisdiction over his state-law claims, dismissed them without prejudice, and denied the defendants’ motion to dismiss as moot.

Holdings

1. The § 1983 claims were barred by Heck because success on Sencial's false-arrest, malicious-prosecution, false-testimony, and related claims would necessarily imply the invalidity of his arrest and criminal prosecution resulting in his four aggravated-assault convictions, and he had not shown that those convictions had been invalidated.
2. The alleged perjury claim would also fail because a police officer is absolutely immune from liability for testimony given as a witness in a criminal proceeding.
3. The court declined to exercise supplemental jurisdiction over Sencial's remaining state-law claims and dismissed them without prejudice because all claims within the court's original jurisdiction had been dismissed and the relevant statutory and discretionary factors favored declining jurisdiction.

Questions Presented

1. Whether Sencial's § 1983 claims challenging the probable cause for his arrest, the validity of his prosecution, and alleged perjury were barred by Heck v. Humphrey despite his not having been convicted of aggravated assault with a firearm.
2. Whether the district court should decline supplemental jurisdiction over Sencial's remaining state-law claims after dismissing all federal claims.
3. Whether the defendants' Rule 12(b)(5) motion challenging service of process should be resolved on the merits.

Disposition

other