Ryan R. King v. Officer Castaneda and Officer Morphew

Summary

A magistrate judge recommends dismissal without prejudice of Ryan R. King's 42 U.S.C. § 1983 action against Officers Castaneda and Morphew following preservice screening under 28 U.S.C. § 1915A. The court concludes that King's claims challenging the officers' reasonable suspicion and resulting detention and arrest are barred by Heck v. Humphrey because success would imply the invalidity of his outstanding no-contact-order conviction. The parties were given fourteen days to file specific objections.

Holdings

1. King’s claims that the officers lacked reasonable suspicion to detain and arrest him are barred by Heck v. Humphrey because a finding in his favor would necessarily invalidate his outstanding conviction for violating a no-contact order.
2. The complaint should be dismissed without prejudice for failure to state a claim upon which relief may be granted.

Questions Presented

1. Whether King’s § 1983 claims challenging the officers’ reasonable suspicion to detain and arrest him are cognizable when success on those claims would necessarily imply the invalidity of his outstanding state conviction.
2. Whether the complaint should be dismissed without prejudice under the preservice screening requirements of 28 U.S.C. § 1915A.

Disposition

dismissed