Bingham v. Churchill

District Court, E.D. Virginia·Decided April 23, 2025·No. 1:25-cv-00119·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division Ta’Kuan Bingham, ) Plaintiff, ) ) v. ) No. 1:25cv119 (RDA/LRV) ) Julie Lillrose Churchill, ) Defendant. ) MEMORANDUM OPINION AND ORDER Ta’Kuan Bingham (“Plaintiff or “Bingham’”), a Virginia inmate proceeding pro se, has filed a civil rights complaint pursuant to 42 U.S.C. § 1983, alleging that the defendant violated his constitutional rights. Dkt. No. 1. Bingham has applied to proceed in forma pauperis, Dkt. No. 2, and seeks monetary relief and retrial. Dkt. No. 1 at 2. Because Bingham is a prisoner, however, the Court must screen his complaint to determine whether it is frivolous, malicious, or fails to state any claims upon which relief may be granted. See 28 U.S.C. § 1915A.! I. Standard of Review Pursuant to § 1915A, this Court must dismiss any claims based upon “‘an indisputably meritless legal theory,’” or claims where the “factual contentions are clearly baseless.” Clay v.

' Section 1915A provides: (a) Screening.—The court shall review, before docketing, if feasible or, in any event, as soon as practicable after docketing, a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental! entity. (b) Grounds for dismissal.—On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint— (1) is frivolous, malicious, or fails to state a claim upon which relief can be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.

Yates, 809 F. Supp. 417, 427 (E.D. Va. 1992) (quoting Neitzke v. Williams, 490 U.S. 319, 327 (1989)). The second standard is the familiar standard for a motion to dismiss under Federal Rules of Civil Procedure 12(b)(6). “A motion to dismiss under Rule 12(b)(6) tests the sufficiency of a complaint; importantly, it does not resolve contests surrounding the facts, the merits of a claim, or the applicability of defenses.” Republican Party of N.C. v. Martin, 980 F.2d 943, 952 (4th Cir. 1992) (citation omitted). In considering a motion to dismiss for failure to state a claim, a plaintiff's well-pleaded allegations are taken as true and the complaint is viewed in the light most favorable to the plaintiff. See Mylan Labs., Inc. v. Matkari, 7 F.3d 1130, 1134 (4th Cir. 1993); see also Martin, 980 F.2d at 952. In addition, under 28 U.S.C. § 1915(e)(2)(B), a complaint can be dismissed at any time if the Court determines it fails to state a claim upon which relief can be granted, is frivolous or without merit when it is clear it would be barred by the statute of limitations. See Nasim v. Warden, Ma. House of Correction, 64 F.3d 951, 955-56 (4th Cir. 1995) (en banc) (affirming district court’s finding that complaint was barred by the applicable statute of limitations and “that the district court did not abuse its discretion in concluding that the action was frivolous”) (citing 28 U.S.C. § 1915(d)); Brown vy. Harris, No. 3:10cv613, 2012 WL 12383, at *1 (E.D. Va. Jan. 3, 2012) (under 28 U.S.C. § 1915(e)(2), a court must dismiss claims barred by the relevant statute of limitations (citing Eriline Co. S.A. v. Johnson, 440 F.3d 648, 655-57 (4th Cir. 2006)). II. Complaint Bingham alleges that his trial counsel, Defendant Julie Lillrose Churchill, violated his constitutional rights because she “coerced” his guilty plea in Gloucester County Circuit Court and she failed to argue that he be sentenced to “time served.” Dkt. No. 1 at 2-4. On August 17, 2021, Bingham pleaded guilty to arson of an occupied dwelling and three counts of animal cruelty.

Bingham v. Commonwealth, Record No. 1396-21-1, 2022 WL 1547984, at *1-4 (Va. Ct. App. May 17, 2022). The complaint is largely conclusory and contains little more than that which is summarized above. The online records of the Gloucester County Circuit Court confirm that Bingham was convicted of the arson of an occupied dwelling, and three counts of animal cruelty on November 8, 2021.? Bingham, by counsel, appealed his convictions to the Virginia Court of Appeals, which affirmed his convictions on May 17, 2022. Bingham v. Commonwealth, Record No. 1396-21-1,

2 The online records for the Gloucester County Circuit Court indicate that Bingham was indicted on July 6, 2021, entered his guilty pleas on August 17, 2021, and that the court denied his motion to withdraw his pleas at his sentencing on November 8, 2021. See https://www.vacourts.gov/, Case Status and Information, Circuit Court Case Information and Fee Calculation, Gloucester Circuit Court, Criminal Tab (search “Bingham, Ta’Kuan”) (last searched Apr. 22, 2025). See Colonial Penn Ins. Co. v. Coil, 887 F.2d 1236, 1239 (4th Cir. 1989) (“most frequent use of judicial notice of ascertainable facts is in noticing the content of court records”) (collecting cases); see, e.g., Lynch v. Leis, 382 F.3d 642, 647 & n.5 (6th Cir. 2004) (taking judicial notice of state court records available to public online). His federal habeas petition indicates that Defendant Churchill represented Bingham from indictment through his plea on August 17, 2021. See Bingham y. Anderson, No. 1:24-cv-01225-RDA-WBP, Dkt. No. | at 13. Bingham’s petition for a writ was dismissed without prejudice on February 27, 20225, and is pending on appeal. The habeas challenges the same four convictions he references in his § 1983, as well as a larceny conviction. /d., Dkt. No. 1 at 1. Further, although Bingham seeks to be retried, such relief is not available via a § 1983 civil action. Where, as here, a complaint attacks the fact or duration of confinement, the appropriate remedy is a writ of habeas corpus, not a claim under 42 U.S.C. § 1983. See Preiser v. Rodriguez, 411 U.S. 475, 487 (1973). See generally Wilkinson v. Dotson, 544 U.S. 74, 78-82 (2005) (summarizing the distinctions between § 1983 and habeas actions). As the Supreme Court has noted, a § 1983 claim for unconstitutional imprisonment is not appropriate unless and until plaintiff's 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... .” Heck v. Humphrey, 512 U.S. 477, 486-87 (1994); see also Edwards v. Balisok, 520 U.S. 641, 646-47 (1997) (recognizing a valid § 1983 claim when the procedural claim at issue does not call into question the lawfulness of plaintiff's continuing confinement),

2022 WL 1547984, at *4 (Va.

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