Russell Eric Lenard v. State of Tennessee and Tim Wilson

Summary

The United States District Court for the Eastern District of Tennessee construes Russell Eric Lenard’s filings as claims under 42 U.S.C. § 1983 rather than habeas claims. The court denies his request for appointed counsel, dismisses his constitutional claims under Heck v. Humphrey, declines supplemental jurisdiction over state-law claims, and directs the Clerk to provide a § 2254 petition form. The action is dismissed under the Prison Litigation Reform Act, and the court certifies that an appeal would not be taken in good faith.

Holdings

1. The court construed Lenard's relevant filings as seeking relief under 42 U.S.C. § 1983 rather than under 28 U.S.C. § 2254 because the pleadings primarily asserted tort, contract, and constitutional claims, and any habeas claims had not been exhausted in state court.
2. Lenard was not entitled to appointment of counsel because he failed to show exceptional circumstances.
3. Lenard's claims challenging the validity of his criminal convictions based on counsel's conduct and the alleged invalidity of his guilty plea were not cognizable under § 1983 because success would imply the invalidity of the convictions, and the convictions had not been invalidated.
4. To the extent Lenard sought release from confinement based on the convictions, he was required to pursue that relief through a petition for a writ of habeas corpus rather than through § 1983.
5. After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over Lenard's remaining state-law claims and dismissed them without prejudice.

Questions Presented

1. Whether the prisoner's pleadings should be construed as claims under 42 U.S.C. § 1983 or as a petition for federal habeas corpus relief under 28 U.S.C. § 2254.
2. Whether the prisoner was entitled to appointment of counsel in the civil action.
3. Whether claims whose success would imply the invalidity of criminal convictions are cognizable under § 1983 before those convictions have been invalidated.
4. Whether claims seeking release from confinement must be brought through habeas corpus rather than § 1983.
5. Whether the court should exercise supplemental jurisdiction over the remaining state-law claims after dismissing the federal claims.

Disposition

dismissed