Summary
The Northern District of California dismissed Gregory Brown’s pro se 42 U.S.C. § 1983 action against San Francisco and state officials under Heck v. Humphrey. The court concluded that a judgment in Brown’s favor would necessarily imply the invalidity of his convictions or sentence, which had not been shown to have been reversed or otherwise invalidated.
Topics
Practice areas
Questions Presented
- Whether Brown's § 1983 claims were cognizable when success on those claims would necessarily imply the invalidity of his convictions or sentence.
- Whether the complaint stated a plausible claim under § 1983 sufficient to survive initial screening under 28 U.S.C. § 1915(e).
Holdings
- A prisoner's § 1983 action seeking damages for an allegedly unconstitutional conviction, imprisonment, or related harm is not cognizable when a judgment in the prisoner's favor would necessarily imply the invalidity of the conviction or sentence, unless the conviction or sentence has already been invalidated through one of the means identified in Heck v. Humphrey. Brown's claims were barred because the alleged constitutional violations concerned the securing and continued validity of his convictions and sentence.
- A § 1983 complaint must allege a violation of a constitutional or federal right by a person acting under color of state law, and conclusory allegations do not satisfy the plausibility requirement. The complaint was dismissed at initial screening.
Key quotations
“Heck v. Humphrey, 512 U.S. 477, 486-487 (1994), bars claims brought under 42 U.S.C. § 1983 that, if successful, would appear to invalidate a conviction or sentence that has not already been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court’s issuance of a writ of habeas corpus.” (at 1)
“Accordingly, where a state prisoner seeks damages in a section 1983 suit, the district court must consider whether a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence.” (at 2)
Factual background
Brown, a California state prisoner, is serving a sentence of 56 years to life for 1995 convictions for conspiracy to commit murder and attempted murder. His appeals and petitions for resentencing have been denied. He sued San Francisco and several prosecutors and government attorneys, alleging that they violated his constitutional rights in securing his convictions and in opposing his efforts to overturn or reduce his convictions and sentence.
Procedural history
Gregory Brown is serving a sentence of 56 years to life for 1995 California convictions for conspiracy to commit murder and attempted murder. His appeals and resentencing petitions were denied. He then filed this federal civil-rights action challenging conduct connected with obtaining his convictions and opposing his efforts to overturn or reduce them. The district court dismissed the action and directed the Clerk to enter judgment for defendants and close the file.