Brian Peak v. Paige Kristyn Wheeler, et al.

Summary

The court granted Brian Peak leave to proceed in forma pauperis but assessed an initial partial filing fee of $1.00. The court dismissed the action without prejudice under 28 U.S.C. § 1915(e)(2)(B), holding that the claims were barred or deficient based on sovereign, prosecutorial, and judicial immunity, Younger abstention, lack of municipal liability allegations, and failure to exhaust state remedies regarding bond. The court denied the plaintiff’s requests for injunctive relief and appointment of counsel as moot.

Holdings

1. Claims against the prosecutor in her official capacity were treated as claims against the State of Missouri and were barred by the Eleventh Amendment because neither congressional abrogation nor state waiver applied.
2. The prosecutor was absolutely immune from Peak's individual-capacity claims because the challenged conduct involved prosecutorial advocacy in the initiation and prosecution of a criminal case.
3. Peak's claims against the state judges were barred by absolute judicial immunity because the challenged conduct consisted of judicial acts within their jurisdiction.
4. Peak failed to state a § 1983 claim against Knox County Circuit Court because he did not plead an official policy, unofficial custom, or deliberately indifferent failure to train or supervise, and the court itself was not a suable juridical entity.
5. Younger abstention required dismissal of Peak's requests to enjoin or otherwise interfere with his ongoing state criminal proceedings because the proceedings implicated important state interests and no extraordinary circumstance was shown.
6. Peak's excessive-bond claim was dismissed because challenges to pretrial custody and bond were subject to 28 U.S.C. § 2241 and available state remedies had not been exhausted.

Questions Presented

1. Whether Peak's claims against the prosecutor in her official and individual capacities were barred by sovereign immunity and prosecutorial immunity.
2. Whether Peak's claims against the state judges were barred by judicial immunity.
3. Whether Peak adequately pleaded a claim against Knox County Circuit Court or a local governmental entity under 42 U.S.C. § 1983.
4. Whether Younger abstention barred federal intervention in Peak's ongoing state criminal proceedings.
5. Whether Peak's challenge to his bond was cognizable in this § 1983 action before exhaustion of available state remedies.

Disposition

dismissed