Kennemer v. Tyler

District Court, D. Idaho·Decided May 5, 2025·No. 3:25-cv-00032·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

KELLY KENNEMER, Case No. 3:25-cv-00032-BLW Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

E. CLAYNE TYLER,

Defendant.

The Clerk of Court conditionally filed Plaintiff Kelly Kennemer’s Complaint because of Plaintiff’s status as an inmate and in forma pauperis request. A “conditional filing” means that a plaintiff must obtain authorization from the Court to proceed. Upon screening, the Court must dismiss claims that are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b). Having reviewed the record, the Court concludes that the Complaint fails to state a claim upon which relief may be granted. Accordingly, the Court enters the following Order directing Plaintiff to file an amended complaint if Plaintiff intends to proceed. 1. Standards of Law for Screening Complaints A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A complaint fails to state a claim for relief under Rule 8 if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

To state an actionable claim, a plaintiff must provide “enough factual matter (taken as true) to suggest” that the defendant committed the unlawful act, meaning that sufficient facts are pled “to raise a reasonable expectation that discovery will reveal evidence of illegal [activity].” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of

a cause of action will not do.’” Iqbal, 556 US. at 678 (quoting Twombly, 550 U.S. at 555). The Court liberally construes the pleadings to determine whether a case should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional

claim, however inartfully pleaded, has an arguable factual and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000). Moreover, even if a complaint meets the pleading requirements, dismissal under §§ 1915 and 1915A is still appropriate if an affirmative

defense is an “obvious bar to securing relief on the face of the complaint.” Washington v. Los Angeles Cnty. Sheriff’s Dep’t, 833 F.3d 1048, 1056 (9th Cir. 2016) (internal quotation marks omitted). A court is not required to comb through a plaintiff’s exhibits or other filings to determine if the complaint states a plausible claim. Therefore, in its review under §§ 1915 and 1915A, the Court has reviewed only the Complaint found at Docket No. 3, not the

police report or other documents attached to the Complaint. See General Order 342, In Re: Procedural Rules for Prisoner Civil Case Filings and for Prisoner E-Filing Program, § A(1)(b) and (c) (“No exhibits may be attached to a complaint or any type of amended complaint, except those showing exhaustion of administrative remedies[,] [and] [n]o affidavits may be attached to a complaint or any type of amended complaint.”).

2. Factual Allegations Plaintiff is an inmate in the Clearwater County Jail. Plaintiff alleges that Defendant Tyler, the prosecutor in Plaintiff’s state court criminal case, violated Plaintiff’s rights by suborning perjury from a police officer in the course of that case. Compl., Dkt. 3, at 2. Plaintiff also alleges that Defendant conspired with Defendant’s wife, a

Clearwater County Jail nurse, to “deny treatment that would have yielded exculpatory evidence,” which Plaintiff could have presented in his criminal case. Id. 3. Discussion Plaintiff has not stated a claim upon which relief may be granted. The Court will, however, grant Plaintiff 28 days to amend the Complaint. Any amended complaint should take into consideration the following.

A. Section 1983 Claims Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). A defendant causes a constitutional deprivation within the meaning of § 1983 “if he does

an affirmative act, participates in another’s affirmative acts, or omits to perform an act which he is legally required to do that causes the deprivation.” Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). i. Claim of Prosecutorial Misconduct in the Course of Plaintiff’s Prosecution Plaintiff claims Defendant knew that a witness testified falsely in Plaintiff’s criminal case. If Plaintiff has been convicted of the charges against him, then this claim is likely barred by Heck v. Humphrey, 512 U.S. 477 (1994). In Heck, the United States

Supreme Court held that a civil rights claim “is not cognizable under § 1983” if the plaintiff’s success would “render a conviction or sentence invalid.” Id. at 486–87. That is, a § 1983 action “is barred if—but only if—success in the action … would necessarily imply or demonstrate that the plaintiff’s earlier conviction was invalid.” Lemos v. Cnty. of Sonoma, 40 F.4th 1002, 1006 (9th Cir. 2022) (en banc) (internal

quotations and citation omitted). To overcome this bar, a plaintiff must show either that (1) the action, if successful, would not necessarily “demonstrate the invalidity of any outstanding criminal judgment” or (2) “the conviction or sentence has already been invalidated.” Id. at 1005 (quoting Heck, 512 U.S. at 487). The Complaint does not plausibly allege that Plaintiff’s misconduct claim would be allowed to proceed under

Heck. If, instead of Plaintiff having been convicted, the charges against Plaintiff are still pending, then Plaintiff’s prosecutorial misconduct claim is likely barred by a different legal doctrine that was announced in Younger v. Harris, 401 U.S. 37 (1971). Under

Younger, a federal court can hear a civil rights claim related to a pending state criminal case only if “the threat to the plaintiff’s federally protected rights … cannot be eliminated by his defense against a single criminal prosecution.” Id. at 46.

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