Snyder v. United States

CourtDistrict Court, D. Idaho
DecidedJanuary 21, 2025
Docket1:23-cv-00176
StatusUnknown

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

Bluebook
Snyder v. United States, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

JAMES FRANKLIN SNYDER,

Plaintiff, Case No. 1:23-cv-00176-BLW

vs. SECOND SUCCESSIVE REVIEW ORDER CITY OF COEUR D’ALENE, BY SCREENING JUDGE KOOTENAI COUNTY, CHAD PAGE, WARDEN RANDY VALLEY, WARDEN JANE DOE, WARDEN JOHN DOE 1-2, DIANE REMACLE, EMMA WILSON, and MELISSA CARR,

Defendants.

The Court has reviewed the Second Amended Complaint of Plaintiff James Franklin Snyder. Dkt. 26. This civil rights case challenges various aspects of Kootenai County case CR28-19-6825, Idaho v. Snyder (“Case 6825”)—from arrest and pretrial stage through conviction, several probation grants and revocations, and a final relinquishment of jurisdiction that required Plaintiff to serve his sentence. Also pending before this Court is Plaintiff’s related successive habeas corpus petition in Case 1:24-cv- 00336-BLW, Snyder v Ross, which gives the Court insight into Plaintiff’s pro se efforts to identify valid claims and determine how to present to the courts in a manner in which the claims will be heard. The screening standard of law for pro se prisoner complaints is set forth in the Court’s prior Order and is not repeated here. For the reasons that follow, Plaintiff will be permitted to proceed to the next stage of litigation on only the retaliation claims against

only the prison case managers. 1. Background The Idaho Court of Appeals described Plaintiff’s criminal history as follows: James Franklin Snyder pled guilty to possession of a controlled substance [on June 4, 2019].1 I.C. § 37-2732(c)(1). In exchange for his guilty plea, an additional charge and an allegation that he is a persistent violator were dismissed. The district court sentenced Snyder to a unified term of seven years, with a minimum period of confinement of three years. The district court suspended the sentence and placed Snyder on probation. Snyder admitted to violating the terms of his probation. The district court revoked probation, ordered execution of his sentence, but retained jurisdiction.

State v. Snyder, No. 49736, 2023 WL 2489842, at *1 (Idaho Ct. App. Mar. 14, 2023), cert. denied, 143 S. Ct. 2678 (2023). Plaintiff also appealed denial of a Rule 35 motion to reduce his sentence. Id. Additional case history shows: After Snyder completed his rider, the district court again suspended the sentence and placed Snyder on probation. Snyder admitted to violating the terms of his probation. The district court revoked Snyder’s probation and ordered execution of his original sentence. Snyder filed an I.C.R. 35 motion, which the district court granted by again retaining jurisdiction. Before completion of the rider and based on information in an addendum to his presentence investigation

1 For dates and other docket facts, see Idaho Supreme Court register of actions for Kootenai County case CR28-19- 6825, Idaho v. Snyder (accessed 1/6/2025). report, the district court held a hearing and ultimately relinquished jurisdiction.

State v. Snyder, No. 50428, 2023 WL 7181444, at *1 (Idaho Ct. App. Nov. 1, 2023). The state district court’s relinquishment of jurisdiction was affirmed on appeal. See id. 2. Defamation, Slander, and Libel Claims A. Heck v. Humphrey Bar In this civil rights case, Plaintiff brings defamation, slander, and libel claims (together “defamation claims”) against “the wardens for the city, county, and prison”; the “chief”; three prison case managers; and two municipal entities. Dkt. 26 at 2. He asserts that various government officials changed his Washington state criminal history to create

false information that the Idaho state court relied upon to sentence him and revoke his probation. In particular, he asserts that he was wrongfully labelled “the highest ranking Mexican Mafia member in Washington State.” Id. This caused him to be falsely arrested on the charges in Case 6825, and to be brutally attacked by the Mexican Mafia, who ran over him with a semi-truck at 67 miles per hour. Id. at 1-4. Defendants also allegedly

“went back in Snyder’s criminal history adding in 2004 child molestation charges and rape charges.” Id. at 6. He asserts that all of these rumors spread throughout the small towns near Plaintiff’s residence, negatively affecting his livelihood. Id. at 5. The Court previously warned Plaintiff that he could not proceed on claims related to his criminal conviction or to his probation revocations that fall within the bar of Heck

v. Humphrey, 512 U.S. 477, 486-87 (1994). In Heck, the Supreme Court held that, where a favorable verdict in a civil rights action would necessarily imply that a plaintiff’s conviction or sentence is invalid, he must first prove that the conviction or sentence has been overturned before the civil rights action can proceed. Id. Such a claim is not cognizable under § 1983. Id. Heck applies to civil rights cases challenging probation

violation charges and probation revocations. See Jackson v. Vannoy, 49 F.3d 175, 177 (5th Cir. 1995). If success would not imply invalidity of a conviction or sentence, “the action should be allowed to proceed, in the absence of some other bar to the suit.” Heck, 512 U.S. at 487 (footnote omitted); Edwards v. Balisok, 520 U.S. 641 (1997) (applying same principle to civil rights actions challenging deprivation of prison good-time credits

that would otherwise shorten an inmate’s sentence). Plaintiff recently completed his sentence and was released, which impacts the Heck analysis. In Spencer v. Kemna, 523 U.S. 1 (1998), in the habeas corpus context, the Court held that, while an ex-prisoner’s pending habeas petition challenging his underlying conviction does not become moot upon his release due to the continuing

consequences of a criminal record, the petitioner’s challenge to his parole revocation was mooted by his release from custody. See id. at 7–13. But, in dicta, five Justices in Spencer “suggested that Heck’s scope might be narrower than Heck itself indicated.” Lyall v. City of Los Angeles, 807 F.3d 1178, 1190 (9th Cir. 2015). The Justices seemed to agree that a petitioner could bring such a claim under § 1983 without satisfying Heck’s favorable-

termination requirement, as “it would be impossible as a matter of law for him to satisfy” that requirement due to the unavailability of habeas relief. Id. at 1190-91. In the § 1983 context, the Ninth Circuit Court of Appeals applied the Spencer concurrence’s reasoning and held that Heck did not preclude an ex-prisoner’s § 1983 claim challenging denial of good-time credits for the reason that he could no longer bring that claim in a habeas petition. See Nonnette v. Small, 316 F.3d 872, at 875–76 (9th Cir. 2002). The Ninth Circuit later explained that the Nonnette holding affects only former

prisoners challenging loss of good-time credits, revocation of parole or similar matters”—not challenges to underlying convictions, because ex-prisoners continue to be able to challenge their underlying convictions in habeas after their release. Id. at 878 n.7 (citing Spencer, 523 U.S. at 7–12); see also Lyall, 807 F.3d at 1192 (holding that the plaintiff’s claim “d[id] not come within the narrow exception recognized in Spencer and

Nonnette” because it challenged his underlying conviction). In Guerrero v. Gates, 442 F.3d 697, 704 (9th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Vannoy
49 F.3d 175 (Fifth Circuit, 1995)
Adickes v. S. H. Kress & Co.
398 U.S. 144 (Supreme Court, 1970)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Edwards v. Balisok
520 U.S. 641 (Supreme Court, 1997)
Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Pintos v. PACIFIC CREDITORS ASS'N
605 F.3d 665 (Ninth Circuit, 2010)
Guerrero v. Gates
442 F.3d 697 (Ninth Circuit, 2006)
James Lyall v. City of Los Angeles
807 F.3d 1178 (Ninth Circuit, 2015)
Trevino v. Gates
99 F.3d 911 (Ninth Circuit, 1996)
Cunningham v. Gates
312 F.3d 1148 (Ninth Circuit, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
Snyder v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snyder-v-united-states-idd-2025.