Chad William Reed v. Mark D. Uptegrove, et al.

Summary

The United States District Court for the Eastern District of Oklahoma grants motions to dismiss claims brought under 42 U.S.C. § 1983 by pro se plaintiff Chad William Reed against state judicial and prosecutorial defendants. The court concludes that the claims against Judge Emily Maxwell fail to allege personal participation, claims against Special Judge Mark Uptegrove are barred by the Heck and Rooker-Feldman doctrines and judicial immunity, and several claims against District Attorney Mark Matloff are barred by Heck, untimeliness, or failure to state a claim. All claims are dismissed without prejudice, with a separate judgment to be entered.

Holdings

1. Reed failed to state a claim against Judge Maxwell because he alleged no specific action by her and relied only on speculation that she could influence another judge to protect her husband.
2. Claims against Judge Uptegrove that, if successful, would necessarily imply the invalidity of Reed's conviction or sentence were barred by Heck v. Humphrey because Reed had not shown that his conviction or sentence had been invalidated.
3. To the extent Reed challenged only Judge Uptegrove's application of procedural bars and denial of the post-conviction application, the federal district court lacked jurisdiction under the Rooker-Feldman doctrine.
4. Special Judge Uptegrove was absolutely immune from Reed's claims for civil damages because ruling on Reed's post-conviction application was a judicial act performed in the exercise of judicial discretion.
5. Reed's Napue and Brady claims against Matloff were barred by Heck because success on those claims would imply the invalidity of Reed's conviction or sentence.
6. Reed's First Amendment retaliation claim was barred by Oklahoma's two-year statute of limitations because the alleged retaliatory exchange occurred in 2006 and Reed knew of the alleged injury no later than his 2008 conviction.
7. Reed's Eighth Amendment cruel-and-unusual-punishment claim failed because he was a pretrial detainee during the relevant events and the Eighth Amendment's protections do not apply to pretrial detainees.

Questions Presented

1. Whether Reed stated a § 1983 claim against Judge Emily Maxwell based on speculation that she could influence other judges to protect her husband.
2. Whether Reed's claims against Special Judge Mark Uptegrove were barred by Heck v. Humphrey because success would imply the invalidity of his conviction or sentence.
3. Whether, to the extent Reed challenged only the denial of his post-conviction application, the Rooker-Feldman doctrine deprived the federal district court of jurisdiction.
4. Whether Special Judge Uptegrove was entitled to absolute judicial immunity from Reed's damages claims.
5. Whether Reed's Napue and Brady claims against District Attorney Mark Matloff were barred by Heck.
6. Whether Reed's retaliation claim against Matloff was barred by Oklahoma's two-year statute of limitations.
7. Whether Reed's Eighth Amendment claim against Matloff failed because Reed was a pretrial detainee when the relevant events occurred.

Disposition

dismissed