Joseph Lawson v. State of North Carolina
This text of Joseph Lawson v. State of North Carolina (Joseph Lawson v. State of North Carolina) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
USCA4 Appeal: 21-7524 Doc: 9 Filed: 04/11/2023 Pg: 1 of 4
UNPUBLISHED
UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 21-7524
JOSEPH DWIGHT LAWSON,
Plaintiff - Appellant,
v.
STATE OF NORTH CAROLINA; STOKES COUNTY SHERIFFS DEPARTMENT; OFFICER DENNIS BROWN; JUDGE ANGELA B. PUCKETT; QUINTON HARRIS,
Defendants - Appellees.
Appeal from the United States District Court for the Middle District of North Carolina, at Greensboro. William L. Osteen, Jr., District Judge. (1:21-cv-00433-WO-JLW)
Submitted: November 29, 2022 Decided: April 11, 2023
Before NIEMEYER and RUSHING, Circuit Judges, and TRAXLER, Senior Circuit Judge.
Affirmed in part, vacated in part, and remanded by unpublished per curiam opinion.
Joseph Dwight Lawson, Appellant Pro Se.
Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 21-7524 Doc: 9 Filed: 04/11/2023 Pg: 2 of 4
PER CURIAM:
North Carolina state prisoner Joseph Dwight Lawson filed a 42 U.S.C. § 1983
complaint against the State of North Carolina, the Stokes County Sheriff’s Department,
Officer Dennis Brown, Judge Angela Puckett, and District Attorney Quinton Harris.
Lawson alleged that these Defendants conspired to falsely arrest him so they could steal
his property and convict him of a crime he did not commit. The district court, accepting
the report and recommendation of the magistrate judge, dismissed Lawson’s complaint
under Heck v. Humphrey, 512 U.S. 477 (1994). The district court also dismissed the
complaint as to the state of North Carolina, Judge Puckett, and District Attorney Harris on
the alternate ground that they were entitled to immunity. We affirm in part, vacate in part,
and remand.
Under 28 U.S.C. § 1915A(a), a district court must “engage in a preliminary
screening of any complaint in which a prisoner seeks redress from a governmental entity
or an officer or employee of a governmental entity.” McLean v. United States, 566 F.3d
391, 394 (4th Cir. 2009), abrogated on other grounds by Lomax v. Ortiz-Marquez, 140 S.
Ct. 1721 (2020). A district court must dismiss the complaint if it “is frivolous, malicious,
or fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915A(b)(1). This
Court reviews de novo a dismissal under 28 U.S.C. § 1915A(b)(1), applying the same
standards applicable to review of a Fed. R. Civ. P. 12(b)(6) dismissal. Wilcox v. Brown,
877 F.3d 161, 166 (4th Cir. 2017). “To survive a motion to dismiss, a complaint must
contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible
on its face.” Carey v. Throwe, 957 F.3d 468, 474 (4th Cir. 2020) (internal quotation marks
2 USCA4 Appeal: 21-7524 Doc: 9 Filed: 04/11/2023 Pg: 3 of 4
omitted). “[W]hen a plaintiff raises a civil rights issue and files a complaint pro se, the
court must construe pleading requirements liberally.” Wilcox, 877 F.3d at 167.
In Heck, the Supreme Court held that
when a state prisoner seeks damages in a § 1983 suit, the district court must consider whether a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence; if it would, the complaint must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated. But if the district court determines that the plaintiff’s action, even if successful, will not demonstrate the invalidity of any outstanding criminal judgment against the plaintiff, the action should be allowed to proceed.
512 U.S. at 487.
The district court concluded that a judgment in Lawson’s favor in this case would
necessarily imply the invalidity of his underlying conviction. However, as Lawson
contended before the district court and reiterates on appeal, the primary claim that he seeks
to pursue is a damages claim for false arrest. “[A] claim for false arrest . . . does not by its
nature call into question the validity of a conviction.” Reynolds v. Jamison, 488 F.3d 756,
767 (7th Cir. 2007); see also Gertsein v. Pugh, 420 U.S. 103, 110 (1975) (“[A] conviction
will not be vacated on the ground that the defendant was detained pending trial without a
determination of probable cause.”); Brooks v. City of Winston-Salem, 85 F.3d 178, 182 (4th
Cir. 1996) (“[A] charge that probable cause for a warrantless arrest was lacking, and thus
that the seizure was unconstitutional, would not necessarily implicate the validity of a
subsequently obtained conviction—at least in the usual case.”). Accordingly, the district
court erred in dismissing Lawson’s complaint at the pleading stage as barred by Heck.
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However, the district court correctly found that the State of North Carolina, Judge
Puckett, and District Attorney Harris are entitled to immunity. See Lytle v. Griffith, 240
F.3d 404, 408 (4th Cir. 2001) (“[I]t is well established that an unconsenting State is immune
[by virtue of the Eleventh Amendment] from suits brought in federal courts by her own
citizens as well as by citizens of another State.” (internal quotation marks omitted)); Stump
v. Sparkman, 435 U.S. 349, 355-56 (1978) (discussing well established principle that
judges are absolutely immune from suits for damages for acts committed within their
judicial jurisdiction); Imbler v. Pachtman, 424 U.S. 409, 430-31 (1976) (finding that, as
quasi-judicial officers, prosecutors enjoy absolute immunity when performing
prosecutorial functions as an advocate for the state).
Because the district court erroneously dismissed Lawson’s complaint in its entirety
as barred by Heck, we vacate the district court’s order dismissing Lawson’s complaint as
to Officer Brown and the Sheriff’s Department and remand for further proceedings. We
express no opinion on the merits of Lawson’s false arrest claim. We affirm the judgment
as to the State of North Carolina, Judge Puckett, and District Attorney Harris. We dispense
with oral argument because the facts and legal contentions are adequately presented in the
materials before this court and argument would not aid the decisional process.
AFFIRMED IN PART, VACATED IN PART, AND REMANDED
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