Horne v. Pratt

CourtDistrict Court, S.D. Georgia
DecidedAugust 27, 2025
Docket4:25-cv-00182
StatusUnknown

This text of Horne v. Pratt (Horne v. Pratt) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Horne v. Pratt, (S.D. Ga. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

JORELLE L. HORNE, ) ) Plaintiff, ) ) v. ) CV425-182 ) HARRISON PRATT, ) ) Defendant. ) ORDER Pro se plaintiff Jorelle L. Horne filed this 42 U.S.C. § 1983 action against Assistant District Attorney Harrison Pratt. See doc. 1 at 4-5. The Court granted him leave to proceed in forma pauperis, doc. 4, and he returned the required forms, docs. 6 & 7.1 He has also consented to the undersigned’s jurisdiction over this case. See doc. 8. The Court, therefore, proceeds to screen his Complaint, pursuant to 28 U.S.C.

1 Horne has moved to extend the deadline for his submission of the forms. See doc. 9. That Motion indicates that he mailed them on August 18, 2025. Id. at 1. Pursuant to the Court’s Order granting his request to proceed in forma pauperis, doc. 4, the forms were due by August 22, 2025. Fed. R. Civ. P. 6(d). Since, pursuant to the “prison mailbox rule,” they are deemed filed on the date he mailed them, i.e. August 18, they are timely, see, e.g., Washington v. United States, 243 F.3d 1299, 1301 (11th Cir. 2001), and his request to extend the deadline is DISMISSED as moot. Doc. 9. § 1915A. For the reasons explained below, his Complaint is DISMISSED. Doc. 1.

The Court applies Federal Rule of Civil Procedure 12(b)(6) standards in screening a complaint pursuant to § 1915A, Leal v. Ga. Dep’t of Corr., 254 F.3d 1276, 1278-79 (11th Cir. 2001), so allegations in the

Complaint are taken as true and construed in the light most favorable to the plaintiff. Bumpus v. Watts, 448 F. App’x 3, 4 n.1 (11th Cir. 2011).

Conclusory allegations, however, fail. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (discussing a Rule 12(b)(6) dismissal). Because Plaintiff is proceeding pro se, his pleadings are held to a less stringent standard than

pleadings drafted by attorneys and are liberally construed. See Bingham v. Thomas, 654 F.3d 1171, 1175 (11th Cir. 2011). Horne alleges that Defendant Pratt, a Chatham County Assistant

District Attorney, violated his constitutional rights “at [Horne’s] jury trial,” because he granted several witnesses immunity. See doc. 1 at 5. He claims that Defendant Pratt’s decision was motivated by racial

animus. Id. Horne indicates that he was ultimately convicted. Id. at 5- 6. He seeks monetary damages and an injunction concerning his continued detention directed to a Chatham County Superior Court judge. Id. at 7. Pretermitting whether the Court could properly issue an injunction against a non-party state judicial officer, Horne fails to state

any plausible claim for relief. For the reasons explained below, his Complaint is dismissed. To the extent Horne asks this Court to weigh in on the propriety of

ongoing state proceedings—i.e., the referenced “timely appeals,” doc. 1 at 7—against him, any ruling by this Court could substantially interfere

with the results reached in the state court proceeding. See 31 Foster Children v. Bush, 329 F.3d 1255, 1276 (11th Cir. 2003) (noting the importance of “whether the federal proceeding will interfere with an

ongoing state court proceeding” in determining whether abstention is appropriate). Pursuant to Younger v. Harris, 401 U.S. 37, 53 (1971), federal courts must abstain from hearing claims that would interfere

with pending state criminal proceedings, provided that the party seeking federal relief has an adequate remedy at law and has not shown that he will suffer irreparable injury. Plaintiff, obviously, remains free to allege

constitutional and procedural violations in his state criminal proceedings. He thus cannot demonstrate the lack of an adequate remedy at law nor irreparable injury. Younger, 401 U.S. at 46 (“Certain types of injury, in particular, the cost, anxiety, and inconvenience of having to defend against a single criminal prosecution, could not by

themselves be considered ‘irreparable’ in the special legal sense of that term.”). Thus, any such arguments are for the state court. See also Heck v. Humphrey, 512 U.S. 477, 487 n. 8 (1994) (“[I]f a state criminal

defendant brings a federal civil-rights lawsuit during the pendency of his criminal trial, appeal, or state habeas action, abstention may be an

appropriate response to the parallel state-court proceedings.”). Additionally, even if this Court could weigh in on Horne’s allegations, his claims against the named defendant are fatally defective.

Defendant Pratt is immune from suit. Prosecutors are immune from § 1983 liability where their alleged malfeasance stems from their “function as advocate.” Jones v. Cannon, 174 F.3d 1271, 1281 (11th Cir.

1999). They enjoy “absolute immunity for the initiation and pursuit of criminal prosecution,” even when accused of perjury. Id.; see also Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutorial immunity applied to

allegations prosecutor knowingly used perjured testimony and suppressed material evidence at trial); Jackson v. Capraun, 534 F. App’x 854, 859 (11th Cir. 2013) (prosecutor entitled to absolute immunity for initiating prosecution even if he did so with malicious intent); Fullman v. Graddick, 739 F.2d 553, 559 (11th Cir. 1984) (determining prosecutor

entitled to immunity from § 1983 liability for allegedly conspiring to withhold evidence and to create and proffer perjured testimony). Prosecutorial immunity “extends to a prosecutor’s ‘acts undertaken

. . . in preparing for the initiation of judicial proceedings or for trial, and which occur in the course of his role as an advocate for the State.’” Jones,

174 F.3d at 1281 (citation omitted). Prosecutorial immunity applies, for instance, to the prosecutor’s actions in initiating a prosecution and presenting the State’s case. A prosecutor is immune for malicious prosecution. Prosecutors are immune for appearances before a court and conduct in the courtroom, including examining witnesses and presenting evidence in support of a search warrant during a probable cause hearing.

Hart v. Hodges, 587 F.3d 1288, 1295 (11th Cir. 2009) (citations omitted). Courts have also expressly recognized that a “prosecutors decision to grant immunity to a witness in return for providing testimony[ ] are . . . barred by prosecutorial immunity, regardless of whether that action was motivated by animus . . . .” Dillard v. Sanchez, 2007 WL 1072117, at *3 (D. Or. Apr. 5, 2007). Since the only conduct that Horne references in his Complaint involves prosecutorial decisions Pratt made in the course of a jury trial, there is simply no doubt that Pratt enjoys absolute immunity against any claim arising from that conduct.

Accordingly, Horne’s Complaint is DISMISSED. Doc. 1.

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Related

Jones v. Cannon
174 F.3d 1271 (Eleventh Circuit, 1999)
Hart v. Hodges
587 F.3d 1288 (Eleventh Circuit, 2009)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Thomas B. Fullman v. Charles Graddick
739 F.2d 553 (Eleventh Circuit, 1984)
Bingham v. Thomas
654 F.3d 1171 (Eleventh Circuit, 2011)
Sirica Bumpus v. Harrell Watts, Mr Peterson
448 F. App'x 3 (Eleventh Circuit, 2011)
Ronald Washington, A.K.A. Boo Washington v. United States
243 F.3d 1299 (Eleventh Circuit, 2001)
Adrian Jenkins v. Susan M. Walker
620 F. App'x 709 (Eleventh Circuit, 2015)
Darrell L. Jackson v. Eric L. Capraun
534 F. App'x 854 (Eleventh Circuit, 2013)

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Horne v. Pratt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/horne-v-pratt-gasd-2025.