Sturgeon v. Welsh

CourtDistrict Court, D. Idaho
DecidedFebruary 6, 2025
Docket1:24-cv-00377
StatusUnknown

This text of Sturgeon v. Welsh (Sturgeon v. Welsh) 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
Sturgeon v. Welsh, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

IAN ALEXANDER STURGEON, Case No. 1:24-cv-00377-DCN Plaintiff, INITIAL REVIEW ORDER v. BY SCREENING JUDGE

WHITNEY WELSH, ALEXA ADAMS, JULIE BRYANT, MOIRA LYNCH, JEREMY WALLINGFORD, and GRACE DEWITT,

Defendants.

Plaintiff Ian Alexander Sturgeon (Plaintiff), a prisoner in custody of the Idaho Department of Correction, has filed a civil rights complaint that is subject to screening. See 28 U.S.C. §§ 1915 & 1915A. Having reviewed Plaintiff’s Complaint and Affidavit, the Court issues the following Order permitting him to proceed in part. REVIEW OF COMPLAINT 1. Background

Wyoming and Idaho are parties to the Interstate Compact for Adult Offender Supervision (the Compact), which provides that a probationer in legal custody of a “sending” state may be transferred to a “receiving” state to be supervised. Plaintiff was placed on probation for a conviction in the state of Wyoming, but he had authorization to live and be supervised in Idaho under the Compact, beginning on July 6, 2020. Dkt. 2 at 4. Petitioner had a successful tattoo business in Idaho for several years. Plaintiff’s civil rights claims arise from the intersection of his Wyoming probation and his Idaho arrests and convictions. He sues Whitney Welsh, an Ada County deputy

prosecutor; Grace DeWitt, an Ada County public defender; and Alexa Adams, Julie Bryant, Moira Lynch, and Jeremy Wallingford, all Idaho probation officers or supervisors. Defendants allegedly engaged in a conspiracy to have him falsely arrested and imprisoned on Idaho criminal charges by using agent’s warrants to wrongfully detain him under the guise that the new Idaho criminal charges constituted Wyoming probation violations;

Plaintiff asserts they had no authority to arrest or detain him for the state of Wyoming. Id. at 4. He lost his business and suffered large financial losses and personal property damages as a result of the false arrests. To better understand the sequence of the arrests, convictions, and dismissals Plaintiff refers to, the Court has reviewed and takes judicial notice of the public records

available on the Idaho Supreme Court Register of Actions and attaches those as Exhibits to this Order. On June 21, 2023, Plaintiff was charged with “felony battery - domestic violence with traumatic injury” and a persistent violator enhancement in Ada County. See Exhibit A. A warrant/detention order, a criminal complaint, and a no-contact order all were issued on that date. Petitioner surrendered himself to a probation officer on August 4, 2023.

He was arraigned on August 7, 2023, and was released on bond thereafter. See Exhibit A and Dkt. 2 at 4. On January 16, 2024, he was convicted of the domestic violence offense after jury trial and had the persistent violator enhancement imposed. See Exhibit A. On September 6, 2023, a criminal complaint was filed against Plaintiff for misdemeanor false imprisonment and “misdemeanor battery - domestic violence without traumatic injury against a household member” in Canyon County. See Exhibit B. On October 18, 2023, an affidavit of probable cause was filed. On October 20, 2023, a warrant

was issued for Plaintiff’s arrest. See id. On November 22, 2023, an Ada County prosecutor (Plaintiff asserts that this was Defendant Whitney Welsh, the only prosecutor associated with the Ada County case, see Exhibit A), called Defendant Alexa Adams, a probation official, “inquiring on why Ian had not been arrested under an Agent’s Warrant, despite having three pending felony

charges.” Dkt. 2-1 at 3. On December 8, 2023, Plaintiff was arraigned on the Canyon County misdemeanor domestic violence charge and enhancement. On February 14, 2024, Plaintiff pleaded guilty to both, and judgment was entered in that case. Plaintiff has attached as an exhibit to his Complaint an “agent’s warrant,” dated December 20, 2023. Dkt. 2-1 at 9. The charges were “risk to self or others, drug use, and

not reporting.” Id. He alleges he was wrongfully arrested and then prevented from being arraigned, being eligible for a bond, and being appointed an attorney because agents wrongfully classified the arrest as a probation violation, thus channeling the charges to a parole board preliminary hearing rather than an arraignment. Dkt. 2 at 6; Dkt. 2-1 at 7-8. The corresponding state register of actions shows that charges of felony possession of a

controlled substance, being a persistent violator, and misdemeanor drug paraphernalia were dismissed between January 5, 2024, and February 14, 2024, upon motions of the prosecutor. See Exhibit C. Plaintiff is currently serving his Ada County, Idaho sentences for felony domestic battery and the persistent violator enhancement. His sentences will be satisfied in 2031 and 2043, respectively. He is eligible for parole in 2028.1 2. Standard of Law

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). The Court liberally construes the pleadings to determine whether a case should be dismissed. Under 28 U.S.C. §§ 1915 and 1915A, the Court may dismiss some or all of the claims in a complaint for any of the following reasons:

 “insufficient facts under a cognizable legal” theory, Robertson v. Dean Witter Reynolds, Inc., 749 F.2d 530, 534 (9th Cir. 1984), meaning that the factual assertions, 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);  “lack of a cognizable legal theory,” Robertson, 749 F.2d at 534, including that the complaint fails to state a claim upon which relief may be granted, 28 U.S.C. § 1915(e)(2)(B), or the Court applies a procedural bar sua sponte (on its own) that is often raised as an affirmative defense, Hebrard v. Nofziger, 90 F.4th 1000, 1006 (9th Cir. 2024) (affirming dismissal based on Heck v. Humphrey, 512 U.S. 477 (1994));  frivolousness or maliciousness, 28 U.S.C. § 1915(e)(2)(B); or  seeking monetary relief from a defendant who is immune from such relief, id. To state a claim under 42 U.S.C. § 1983, a plaintiff must allege a violation of rights

1 See https://www.idoc.idaho.gov/content/prisons/resident-client-search/details/136988. 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).

3. Heck v.

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Sturgeon v. Welsh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sturgeon-v-welsh-idd-2025.