Greer v. The Harris County Sheriffs Dept and its Agents

CourtDistrict Court, S.D. Texas
DecidedNovember 29, 2021
Docket4:21-cv-02367
StatusUnknown

This text of Greer v. The Harris County Sheriffs Dept and its Agents (Greer v. The Harris County Sheriffs Dept and its Agents) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Greer v. The Harris County Sheriffs Dept and its Agents, (S.D. Tex. 2021).

Opinion

□ Southern District of Texas ENTERED IN THE UNITED STATES DISTRICT COURT Seer FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION DENNIS WAYNE GREER, JR., a/k/a § DENNIS WAYNE GREEN, § § Plaintiff, § § Civil Action No. H-21-2367 V. § § HARRIS COUNTY SHERIFF’S § OFFICE, et al., § § Defendants. . §

MEMORANDUM OPINION AND ORDER Dennis Wayne Greer, Jr., a/k/a Dennis Wayne Green, proceeding pro se and in forma pauperis, filed a complaint and an amended complaint under 42 U.S.C. § 1983 for unlawful arrest, detention, and criminal prosecution. Plaintiff was a Harris County prisoner and pretrial detainee at the time of filing. He named as defendants “the Harris County Sheriff's Dept. and its Agents, the State of Texas and its Agents, and the United States of America and its Agents, [via] The White House.” (Docket Entries No. 1, 8.) The Court dismissed plaintiff's habeas claims without prejudice and stayed his civil claims pending disposition of his state criminal charges pursuant to Heck v. Humphrey, 512 U.S. 477 (1994). Pending before the Court is plaintiffs motion to lift the stay and to proceed with his civil claims. (Docket Entry No. 9.) In compliance with the Court’s order, plaintiff also filed

a more definite statement of the facts supporting his claims. (Docket Entry No. 11.)

Having considered the motion, the more definite statement, the amended complaint, the record, matters of public record, and the applicable law, the Court GRANTS the motion to lift the stay. Having lifted the stay, the Court DISMISSES this lawsuit for the reasons shown below. I. BACKGROUND AND CLAIMS At the time he filed this lawsuit, plaintiff was in custody of the Harris County Sheriffs Office awaiting trial on five felony and misdemeanor charges for theft of property, violation of a protective order, injury to an elderly person, interference with an emergency telephone call, and interference with the duties of a public servant. Plaintiff claimed that the criminal charges and pretrial detentions were unconstitutional and that his warrantless arrests lacked probable cause. Plaintiff sought monetary compensation, a declaratory judgment, and permanent injunctive relief to enjoin the defendants from violating his constitutional rights. Because the criminal charges were still pending at the time, the Court stayed the lawsuit pursuant to Heck. Plaintiff now seeks to lift the stay and reinstate his lawsuit. In support, he states that he pleaded guilty to a lesser-included offense and was sentenced to time served, and that the other charges were dismissed. Plaintiff contends that his civil claims are no longer barred by Heck and that he is entitled to proceed to trial.

Il. ANALYSIS A. Heck Bar Plaintiff seeks monetary compensation, a declaratory judgment, and injunctive relief

as to his allegedly unlawful arrests, detentions, convictions, and criminal prosecutions. A prisoner’s claim for monetary damages in an action challenging the validity of his confinement and/or conviction are generally barred by the Supreme Court’s decision in Heck

v. Humphrey, 5 12 U.S. 477 (1994). Under Heck, to recover damages based on allegations of unlawful detention or imprisonment, a prisoner must prove that the confinement or conviction has been “reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determinations, or called into question by a federal court’s issuance of a writ of habeas corpus [under] 28 U.S.C. § 2254.” Jd., 512 US. at 486-87. Thus, a plaintiff in a section 1983 lawsuit cannot recover monetary damages or declaratory and injunctive relief unless he alleges and shows that the challenged confinement

or conviction has been invalidated, set aside, or otherwise declared unconstitutional. See, e.g., Mann v. Denton County, 364 F. App’x 881, 883 (Sth Cir. 2010) (per curiam). Public online criminal court records for the Harris County District Clerk’s Office indicate that plaintiff pleaded guilty to two of the five charges and that the remaining three charges were dismissed predicated on plaintiffs guilty pleas in the other two cases. Specifically, the criminal court records show as follows:

(1) On May 27, 2021, plaintiff pleaded guilty to violation of a protective order and was sentenced to ninety days in county jail. State v. Greer, Case No. 2353862 in the County Criminal Court at Law No. 3 of Harris County, Texas. On that same date, the charges for interference with the duties of a public servant were dismissed by the State, premised on plaintiffs conviction in the above case. State v. Greer, Case No. 2338369 in the County Criminal Court at Law No. 3 of Harris County, Texas. On that same date, the charges for theft of property were also dismissed by the State, premised on plaintiff's conviction in Case No. 2353862. State v. Greer, Case No. 2271348 in the County Criminal Court at Law No. 3 of Harris County, Texas. (2) On August 5, 2021, plaintiff pleaded guilty to assault of a family member and was sentenced to one year in county jail. State v. Greer, Case No. 1714486 in the 230th District Court of Harris County, Texas. On that same date, the charges for interference with an emergency request for assistance were dismissed by the State, premised on plaintiffs conviction in the above case. State v. Greer, Case No. 2349362 in the County Criminal Court at Law No. 3 of Harris County, Texas. Plaintiff cannot pursue his section 1983 claims as to the two convictions, as he does not show that they have been invalidated, set aside, or otherwise declared unconstitutional. Thus, those claims remain barred by Heck. Plaintiff fares no better under Heck as to the three dismissed criminal charges. Although the charges were dismissed without a trial, the criminal court records show that the State dismissed the charges based on plaintiffs guilty pleas in the other two cases, and not on the merits of the charges or for lack of probable cause.

Plaintiff fails to show that any charges or arrests were dismissed for lack of probable cause or on the merits of the criminal allegations, and his claims remain barred by Heck. Although plaintiff asserts in his more definite statement that his conviction in Case No. 1714486 was invalidated, reversed, or set aside on August 4, 2021, public online records for the Harris County District Clerk’s Office show that plaintiff was convicted in that case on August 5, 2021. That plaintiff may have pleaded guilty to a lesser-included offense in that

case does not negate the Heck bar. Plaintiff further fails to show that his arrests in any of the dismissed cases were expunged or otherwise set aside, and his claims for relief premised on lack of probable cause remain barred by Heck. Plaintiff provides no factual allegations supporting his claims that the warrantless arrests lacked probable cause. To the contrary, plaintiff states in his more definite statement that his arrests lacked probable cause because, “[i]f investigations were properly handled, charges wouldn’t have been filled [sic].” (Docket Entry No. 11, p. 4.) This assertion does not demonstrate lack of probable cause as to his arrests or prosecution. Plaintiffs claims for monetary damages and declaratory and injunctive relief as to his arrests, pretrial detentions, convictions, and dismissals of certain charges remain barred by Heck, and the claims are DISMISSED WITH PREJUDICE to being asserted again until the Heck conditions are met.

B.

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Related

Jeffrey Mann v. Texas Denton County
364 F. App'x 881 (Fifth Circuit, 2010)
Pratt v. Carroll
12 U.S. 471 (Supreme Court, 1814)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Nieves v. Bartlett
587 U.S. 391 (Supreme Court, 2019)

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Greer v. The Harris County Sheriffs Dept and its Agents, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greer-v-the-harris-county-sheriffs-dept-and-its-agents-txsd-2021.