Moss v. Seawell

CourtDistrict Court, S.D. Georgia
DecidedMay 14, 2020
Docket2:18-cv-00149
StatusUnknown

This text of Moss v. Seawell (Moss v. Seawell) 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
Moss v. Seawell, (S.D. Ga. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA BRUNSWICK DIVISION

BERNARD MOSS, SR.,

Plaintiff, CIVIL ACTION NO.: 2:18-cv-149

v.

DAVID SEAWELL; CHRIS STEWART; CHIEF OF POLICE; and CITY OF BRUNSWICK,

Defendants.

ORDER AND MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION Plaintiff filed this action asserting claims under 42 U.S.C. § 1983.1 Doc. 1 at 1, 3. Plaintiff has also filed a Motion for Leave to Proceed in Forma Pauperis. Doc. 2. For the reasons which follow, I RECOMMEND the Court DISMISS Plaintiff’s Complaint for failure to state a claim upon which relief may be granted, DIRECT the Clerk of Court to CLOSE this case and enter the appropriate judgment of dismissal, and DENY Plaintiff leave to proceed in forma pauperis on appeal. Likewise, I DENY as moot Plaintiff’s Motion for Leave to Proceed in Forma Pauperis in this Court. DISCUSSION I. Plaintiff’s Claims Are Barred Prisoners proceeding in a civil action against officers or employees of government entities must comply with the mandates of the Prison Litigation Reform Act, 28 U.S.C. § 1915

1 In his Complaint, Plaintiff styles this action as one arising under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388, 395–96 (1971). Doc. 1 at 3. However, because no defendant is a federal actor, § 1983 is the proper vehicle. and § 1915A. In determining compliance, the court shall be guided by the longstanding principle that pro se pleadings are entitled to liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972); Walker v. Dugger, 860 F.2d 1010, 1011 (11th Cir. 1988). 28 U.S.C. § 1915A requires a district court to screen the prisoner’s complaint for cognizable claims. The court must dismiss

the complaint or any portion of the complaint that is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary damages from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1) and (2). The same standard for whether to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6) applies to prisoner complaints filed under § 1915(e)(2)(B)(ii). In his Complaint, Plaintiff alleges he was arrested without probable cause and with no arrest warrant. Doc. 1 at 4. Plaintiff asserts after his “illegal arrest,” he was “forced to plead guilty to the charges of murder and rape . . . because he was suffering from ineffective assistance of counsel.” Id. at 4. Plaintiff contends that the court in which he was convicted “should have never allowed the prosecution to force plaintiff to plea guilty or convicted plaintiff after the 4th

Amendment violation occurred . . . .” Id. at 3. As relief, Plaintiff requests monetary damages from each Defendant and that his conviction and sentence be voided and discharged. Id. at 5–6. In general, the distinction between claims which may be brought under § 1983 and those which must be brought as habeas petitions is reasonably well settled. Claims in which state prisoners assert that they are being subjected to unconstitutional punishment not imposed as part of their sentence (e.g., being exposed to an excessive amount of force) are § 1983 actions, not habeas actions. See, e.g., Heck v. Humphrey, 512 U.S. 477, 481–82 (1994). Habeas actions, in contrast, are those that explicitly or by necessary implication challenge a prisoner’s conviction or the sentence imposed on him by a court. Thus, for example, when a prisoner makes a claim that, if successful, could shorten or invalidate his term of imprisonment, the claim must be brought as a habeas petition, not as a § 1983 claim. Id. The remedy Plaintiff seeks—to have his conviction declared void—should be brought as a habeas action. Likewise, Plaintiff is not entitled to monetary damages from Defendants. The Supreme

Court has held: [I]n order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the 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, 28 U.S.C. § 2254. A claim for damages bearing that relationship to a conviction or sentence that has not been so invalidated is not cognizable under § 1983.

Heck, 512 U.S. at 486–87. According to the Heck Court, “when a . . . prisoner seeks damages in a [civil rights] suit, the district court must consider whether a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence.” Id. at 487. If this is the case, the plaintiff’s complaint “must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated.” Id. A district court must determine whether “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, in the absence of some other bar to the suit.” Id. (emphasis in original). A judgment in favor of the Plaintiff in this case would necessarily imply the invalidity if his conviction and sentence, for Plaintiff seeks to void his conviction and sentence based on his “illegal arrest” and “ineffective assistance of counsel.” Doc. 1 at 4. Unless and until Plaintiff’s conviction and sentence have been reversed or overturned, he cannot seek monetary damages for his conviction and sentence. II. Leave to Appeal in Forma Pauperis The Court should also deny Plaintiff leave to appeal in forma pauperis. Though Plaintiff has not yet filed a notice of appeal, it is proper to address these issues in the Court’s order of dismissal. See Fed. R. App. P. 24(a)(3) (trial court may certify that appeal of party proceeding in

forma pauperis is not taken in good faith “before or after the notice of appeal is filed”). An appeal cannot be taken in forma pauperis if the trial court certifies that the appeal is not taken in good faith. 28 U.S.C. § 1915(a)(3); Fed. R. App. P. 24(a)(3). Good faith in this context must be judged by an objective standard. Busch v. County of Volusia, 189 F.R.D. 687, 691 (M.D. Fla. 1999). A party does not proceed in good faith when he seeks to advance a frivolous claim or argument. See Coppedge v. United States, 369 U.S. 438, 445 (1962).

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Moss v. Seawell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moss-v-seawell-gasd-2020.