Balu v. Druckman

District Court, N.D. California·Decided April 29, 2025·No. 3:24-cv-02088·Unknown

Opinion

ARVIND BALU, Case No. 24-cv-02088-SI

Plaintiff, ORDER DENYING PLAINTIFF'S v. RULE 59(E) MOTION TO AMEND THE JUDGMENT REBECCA DRUCKMAN, et al., Re: Dkt. No. 40 Defendants.

The history of this case is known to the parties and was recited by the Court in its prior order from January 7, 2025. See Dkt. No. 38 (“Prior Order”). In the Prior Order, the Court granted defendants’ motions to dismiss on the grounds of res judicata and the statute of limitations. Id. The Court then issued a judgment in favor of defendants. Dkt. No. 39. Plaintiff Arvind Balu timely moved the Court to alter or amend its judgment pursuant to Rule 59(e) of the Federal Rules of Civil Procedure. Dkt. No. 40 (“Mot.”). The Court withheld ruling on the motion until plaintiff’s separate recusal motion was adjudicated.1 For the reasons stated below, the Court DENIES the motion to amend. Rule 59(e) of the Federal Rules of Civil Procedure allows a party to file a motion to alter or amend the judgment of a court within twenty-eight days of that judgment. Fed. R. Civ. P. 59(e). “Amendment or alteration is appropriate under Rule 59(e) if (1) the district court is presented with newly discovered evidence, (2) the district court committed clear error or made an initial decision that was manifestly unjust, or (3) there is an intervening change in controlling law.” Zimmerman v. City of Oakland, 255 F.3d 734, 740 (9th Cir. 2001) (citation omitted). In his motion, plaintiff contends the Court committed numerous errors in its Prior Order. See generally Mot. Plaintiff does not argue that new evidence has surfaced or that the law changed in the month after the Prior Order was issued. I. Procedural Bar to a Malicious Prosecution Claim First and foremost, plaintiff asserts that the Court misinterpreted the state of Ninth Circuit law prior to the Supreme Court’s ruling in Thompson v. Clark, 596 U.S. 36 (2022). See Mot. at 4- 9. Plaintiff continues to argue that he was barred from presenting a claim of malicious prosecution prior to the 2022 Thompson ruling and therefore his claim should not be precluded by res judicata or the statute of limitations. In the Prior Order, the Court explained: Plaintiff creatively argues that the Supreme Court decision in Thompson v. Clark started a new clock for his malicious prosecution claim, but he misunderstands the law. In Heck v. Humphrey, the Supreme Court held that a plaintiff seeking damages for unconstitutional conviction or imprisonment “must prove that the conviction or sentence has 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 . . . .” 512 U.S. 477, 486-87 (1994). Some circuits interpreted Heck to mean that a § 1983 malicious prosecution claim required the plaintiff obtain a finding of innocence. See Thompson, 596 U.S. at 41. While the Supreme Court in Thompson overruled precedent in other circuits that required an “affirmative indication of innocence” before pursuing a malicious prosecution claim under § 1983, 596 U.S. at 41, 48, that had never been the law in the Ninth Circuit. Prior to Thompson, the Ninth Circuit explained that the requirement for favorable termination to pursue a § 1983 suit for wrongful conviction differed from the requirement at common law to show innocence to succeed in the tort of malicious prosecution. Roberts v. City of Fairbanks, 947 F.3d 1191, 1201-03 (9th Cir. 2020). As such, plaintiff was not barred from asserting a timely malicious prosecution claim after his successful writ of habeas corpus—and plaintiff did not receive a new starting clock in 2022. Dkt. No. 38 (emphasis added). The starting point of the analysis is agreed upon: Heck requires a “favorable termination” to proceed with a § 1983 malicious prosecution claim. 512 U.S. 484 n.4. In the wake of Heck, lower courts disagreed about what constituted a “favorable termination.” In Thompson, the Supreme Court posed the question this way: Does it suffice for a plaintiff to show that his criminal prosecution ended without a conviction? Or must the plaintiff also demonstrate that the prosecution ended with some affirmative indication of his innocence, such as an acquittal or a dismissal accompanied by a statement from the judge that the evidence was insufficient? 596 U.S. at 39. The Thompson Court concluded that an “affirmative indication of innocence” was not required; if the criminal prosecution ended without a conviction, that was sufficient. Id. at 49.2 Plaintiff argues this Court errored in its Prior Order by not understanding that a 2004 Ninth Circuit decision barred plaintiff from filing his malicious prosecution claim in 2008, but plaintiff neglects the relevant holding in that case. See Awabdy v. City of Adelanto, 368 F.3d 1062 (9th Cir. 2004). There, the district attorney filed a motion to dismiss charges against a former criminal defendant named Awabdy pursuant to California Penal Code section 1385. Id. at 1066. Awabdy then filed a malicious prosecution action under 42 U.S.C. § 1983 about eighteen months later. Id. The court allowed the claim because [w]hen such a dismissal is procured as the result of a motion by the prosecutor and there are allegations that the prior proceedings were instituted as the result of fraudulent conduct, a malicious prosecution plaintiff is not precluded from maintaining his action unless the defendants can establish that the charges were withdrawn on the basis of a compromise among the parties or for a cause that was not inconsistent with his guilt. Id. at 1068. In essence, this holding puts the “burden” on the subsequent civil defendants to show a prosecutor’s dismissal of charges does not indicate innocence per Heck, rather than requiring the plaintiff to show an affirmative indication of innocence. See Nhia Kao Vang v. Decker, 607 F. App’x 728, 729 (9th Cir. 2015). Plaintiff’s case mirrors Awabdy in crucial ways. Plaintiff’s remaining criminal convictions were reversed after his writ of habeas corpus on May 16, 2006. Balu v. Lake County et al., No. 3:08-cv-03014-SI (N.D. Cal.), Dkt. No. 39, Ex. B. Then, the district attorney moved to dismiss the charges against plaintiff under Penal Code section 1385—the same procedural mechanism as in Awabdy—and the superior court granted the motion on June 19, 2006. Id., Ex. C. Therefore, like Awabdy, plaintiff was able to present a claim for malicious prosecution from that point until the statute of limitations had run. Later, as the Court noted in its Prior Order, the Ninth Circuit in 2020 moved further away from requiring a finding of innocence before proceeding with a malicious prosecution claim under section 1983. See Roberts v. City of Fairbanks, 947 F.3d 1191, 1201-02 (9th Cir. 2020). So even if Awabdy had somehow barred plaintiff from filing this claim in his original 2008 lawsuit, the Heck bar had lifted by 2020, not 2022. The Court recognizes that the Prior Order did not include a full discussion of Awa

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Related

Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Hebbe v. Pliler
627 F.3d 338 (Ninth Circuit, 2010)
Zimmerman v. City Of Oakland
255 F.3d 734 (Ninth Circuit, 2001)
Marvin Roberts v. City of Fairbanks
947 F.3d 1191 (Ninth Circuit, 2020)
Thompson v. Clark
596 U.S. 36 (Supreme Court, 2022)