William David Heffley v. Matt Traster, et al.

Summary

The court denied William David Heffley’s motion to proceed in forma pauperis and dismissed without prejudice his civil-rights complaint against Matt Traster, Neal Blythe, and Kevin Likes. The court held that the claims against the prosecutor were barred by absolute immunity, the allegations against the other defendants were conclusory, and Younger abstention required the court to refrain from interfering with Heffley’s ongoing state criminal prosecution.

Holdings

1. The complaint failed to state plausible claims against Traster and Likes because its allegations were conclusory and did not identify what either defendant specifically did, when the conduct occurred, or how the conduct demonstrated an agreement to retaliate.
2. Blythe was entitled to absolute immunity under 42 U.S.C. § 1983 for conduct related to initiating and prosecuting the state criminal case.
3. The court was required to abstain from hearing Heffley's claims because his state criminal prosecution was ongoing and his requested injunction would interfere with that proceeding.
4. Heffley's motion for leave to proceed in forma pauperis was denied because the complaint failed to state a claim and sought monetary relief against an immune defendant.

Questions Presented

1. Whether the complaint stated plausible claims under 42 U.S.C. §§ 1983 and 1985 against the defendants.
2. Whether prosecutor Neal Blythe was absolutely immune from claims arising from initiating and prosecuting the pending criminal case.
3. Whether the federal court was required to abstain under Younger v. Harris from hearing claims seeking to interfere with the ongoing state criminal prosecution.
4. Whether Heffley should be permitted to proceed in forma pauperis under 28 U.S.C. § 1915.

Disposition

dismissed