Stegemann v. Rensselaer County Sheriff's Office

CourtDistrict Court, N.D. New York
DecidedJanuary 20, 2022
Docket1:15-cv-00021
StatusUnknown

This text of Stegemann v. Rensselaer County Sheriff's Office (Stegemann v. Rensselaer County Sheriff's Office) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stegemann v. Rensselaer County Sheriff's Office, (N.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK __________________________________________ JOSHUA G. STEGEMANN, Plaintiff, vs. 1:15-CV-21 RENSSELAER COUNTY SHERIFF’S OFFICE, et al., Defendants. ___________________________________________ Thomas J. McAvoy, Sr. U.S. District Judge ORDER Defendant entitles the document presently before the Court as his “Third Amended Complaint.” See dkt. # 455. He filed this document after the Second Circuit Court of Appeals issued an opinion affirming the Court’s dismissal of all claims in this case following extensive motion practice. See Mandate, dkt. # 456. The Court dismissed all of Plaintiff’s claims and closed the case and the Court of Appeals affirmed that outcome. Plaintiff contends, however, that he is permitted to file an Amended Complaint in this Court because this court concluded that “‘Plaintiff’s claims which are subject to that Heck bar may be re-plead, BUT ONLY AT SUCH TIME AS PLAINTIFF CAN DEMONSTRATE THAT HE CAN OVERCOME THAT BAR DUE TO A FAVORABLE DETERMINATION FROM SOME OTHER COURT.’” He asserts that the

proposed Amended Complaint seeks damages that overcome that bar, and that the Court 1 of Appeals’s recent decision affirming the Court’ s judgment in this matter permits him to file another complaint. Third Amended Complaint, dkt. #455, at ¶ 2. The instant “Third Amended Complaint” alleges that Defendants, officers in various Sheriff’s Departments and cellular telephone providers,

4. . . . unlawfully monitored, recorded, and disclosed private communications of Joshua G. Stegemann between March 6 through May 6, 2020 and continued to disclose those communications contrary to 18 U.S.C. §§ 2517, 2518(8)(a) to present. Disclosure by law enforcement and others is a compensable violation under 18 U.S.C. §§ 2250. Statutory damages lie from such violations of 18 U.S.C. § 2510 et seq. in the amount of $10,000.00 per defendant and an additional $110,000 for continuing violation.1 5. These defendants intercepted more than 1,800 text messages in violation of any authority and in absence of good faith reliance on any court order because the orders did not authorize interception of text messages. This is a violation of 18 U.S.C. § 2510 et seq. from which Statutory damages lie. Id. at ¶¶ 4-5. That Complaint also refers to an earlier Amended Complaint that Plaintiff filed, contending that “[b]ecause the Appeals Court’s judgment does not dismiss the Statutory Damages sought in the operative pleading (See Dtk. No. 38, at ¶ 58), but does dismiss all other claims contained therein, this amended complaint serves to better facilitate timely resolution of the remaining claims.” Id. at ¶ 3. The Plaintiff is mistaken that the Court of Appeals did not dismiss the damages he alleged in his earlier Complaint. The Court of Appeals addressed Plaintiff’s illegal wiretap claims on appeal. See dkt. # 456 at 6-8. The Court notes that “[t]he Supreme Court’s 1The dates alleged in the Third Amended Complaint do not appear to be accurate if the events alleged are related to the matters underlying this action. The events that gave rise to this lawsuit occurred largely in 2013. Plaintiff was in prison in 2020. The Court will treat those dates as if they were stated in error. If the Plaintiff does intend to file claims regarding events that occurred in 2020, the Court would dismiss the Third Amended Complaint because the events alleged in the Complaint bear no relation to the events that gave rise to the initial lawsuit. Plaintiff would need to file a separate action to address events that occurred in 2020. 2 decision in Heck v. Humphrey ‘precludes the use of § 1983 suits for damages that necessarily have the effect of challenging existing state or federal criminal convictions.” Id. (quoting Proventud v. City of New York, 750 F.3d 121, 124 (2d Cir. 2014)). A complaint that would “necessarily imply the invalidity” of a “conviction of sentence” should be dismissed under this standard. Id. (quoting Heck v. Humphrey, 512 U.S. 477, 487 (1994)). The Court agreed that the Second Circuit’s decision on appeal did not address the merits of his claims that the wiretaps used to convict him were illegal, but instead found that the evidence against him was sufficient to support his conviction even if the wiretap evidence were excluded. Id. at 7-8. As such, Plaintiff's “pursuit of claims in this civil action based on an alleged illegal wiretap, even if successful, would not invalidate his criminal conviction.” Id. at 8. At the same time, however, the Court concluded that Plaintiff's: illegal wiretap claims are still barred on a separate ground under Heck. More specifically, as the Supreme Court explained in Heck, when seeking compensatory damages for an allegedly unreasonable search while the underlying conviction still stands, a plaintiff may recover for an injury other than the harm caused by the conviction and the imprisonment resulting therefrom. 512 U.S. at 487 n.7 . . . Here, Stegemann has not alleged any injury other than his conviction and subsequent imprisonment, which he asserts resulted from the illegal wiretap. Therefore, even though his claims regarding the wiretap may not call his conviction into question, Stegemann cannot recover any damages for these injuries unless and until his conviction, which we affirmed on direct appeal, is overturned. Accordingly, there is no basis to disturb the dismissal of his illegal wiretap claims. Id. (emphasis added). As Plaintiff's own pleading noted, this Court informed Plaintiff that he could only re- plead his claims if a court concluded that the Heck bar no longer applied. The language in the Circuit's opinion makes clear that the Court of Appeals found that the Heck bar did not

permit him to bring his illegal wiretap claims. The Court of Appeals affirmed this Court’s conclusion that the Heck bar applied to this case, and did not find that the Heck bar no longer applied. Moreover, the Court of Appeals did not remand the matter to this Court for consideration of whether Plaintiff could actually seek some other form of damages, but instead concluded that the Court correctly dismissed the wiretap claims on the basis of Heck. Under those circumstances, the Court cannot consider the proposed Third Amended Complaint and will sua sponte dismiss that pleading. In any event, the mandate rule would appear to preclude the Plaintiff from filing an Amended Complaint in this case. “The ‘mandate rule’ has existed since the ‘earliest days’ of the judiciary.” Satek Corp. v. Dev. Specialists, Inc. (In re Courdert Bros., LLP), 809 F.3d 94, 98 (2d Cir. 2015) (quoting Briggs v. Pa. R.R. Co., 334 U.S. 304, 306 (1948)). The rule requires that the lower court “follow the mandate issued by an appellate court.” Id. (quoting Coudert |. Puricelli v. Republic of Argentina, 797 F.3d 213, 218 (2d Cir. 2015)). “The mandate rule ‘.. . forecloses relitigation of issues expressly or impliedly decided by the appellate court.” United States v. Ben Zvi, 242 F.3d 89, 95 (2d Cir.

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Related

Briggs v. Pennsylvania Railroad
334 U.S. 304 (Supreme Court, 1948)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
United States v. Yu Kikumura
947 F.2d 72 (Third Circuit, 1991)
United States v. George Robert Bell
5 F.3d 64 (Fourth Circuit, 1993)
United States v. Luiz Ben Zvi
242 F.3d 89 (Second Circuit, 2001)
Marcos Poventud v. City of New York
750 F.3d 121 (Second Circuit, 2014)
Puricelli v. Republic of Argentina
797 F.3d 213 (Second Circuit, 2015)
Statek Corp. v. Development Specialists, Inc.
809 F.3d 94 (Second Circuit, 2015)

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Bluebook (online)
Stegemann v. Rensselaer County Sheriff's Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stegemann-v-rensselaer-county-sheriffs-office-nynd-2022.