Vasquez v. Bunin

CourtDistrict Court, S.D. Texas
DecidedJanuary 8, 2021
Docket4:20-cv-03944
StatusUnknown

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

Bluebook
Vasquez v. Bunin, (S.D. Tex. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT January 11, 2021 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION MARTIN VASQUEZ, § (TDCJ-CID #1924603) § Plaintiff, § § vs. § CIVIL ACTION H-20-3944 § ALEXANDER BUNIN, et al., § § Defendants. § MEMORANDUM AND OPINION Martin Vasquez, an inmate of the Texas Department of Criminal Justice - Correctional Institutions Division, sued in October 2020, alleging civil rights violations resulting from a denial of due process. Vasquez has not paid the filing fee. From his litigation history, the Court presume he seeks leave to proceed as a pauper. Vasquez, proceeding pro se sues Alexander Bunin, Chief Public Defender; Charles Bacarisse, Harris County District Clerk; Bobby Lumpkin, Director of the TDCJ-CID; and David Gutierrez, Chairman, Texas Board of Pardons and Paroles. The threshold issue is whether Vasquez’s claims should be dismissed as barred by the statute of limitations or as frivolous. I. Vasquez’s Allegations Vasquez explains that he was arrested in 1987, and he was convicted in 1991. Liberally construed, he states that he received probation that was revoked in 1997. He states that the statute requiring sex offender registration was not in effect when he was arrested in 1987. Vasquez asserts that the defendants violated his right to a fair trial. He complains that the evidence was insufficient O:\RAO\VDG\2020\20-3944.a01.wpd to support his conviction. He argues that he is falsely imprisoned. Online records show that Vasquez was convicted of sexual assault of a child in Cause Number 548808 in 1989. He was later convicted of failure to register as a sex offender in Cause Number 861633 in 2000.

II. Discussion A federal court has the authority to dismiss an action in which the plaintiff is proceeding in forma pauperis before service if the court determines that the action is frivolous or malicious. 28 U.S.C. § 1915(e)(2)(B)(i). A complaint is frivolous if it lacks an arguable basis in law or fact. See Denton v. Hernandez, 504 U.S. 25, 31 (1992); Richardson v. Spurlock, 260 F.3d 495, 498 (5th Cir. 2001) (citing Siglar v. Hightower, 112 F.3d 191, 193 (5th Cir. 1997)). “A complaint lacks an arguable basis in law if it is based on an indisputably meritless legal theory, such as if the complaint alleges the violation of a legal interest which clearly does not exist.” Davis v. Scott, 157 F.3d 1003,

1005 (5th Cir. 1998) (quoting McCormick v. Stalder, 105 F.3d 1059, 1061 (5th Cir. 1997)). Dismissal of an action is appropriate when “it is clear from the face of a complaint filed in forma pauperis that the claims asserted are barred by the applicable statute of limitations.” Gartrell, 981 F.2d at 256. In section 1983 cases, the federal courts apply the forum state’s general personal injury statute of limitations. Burge v. Parish of St. Tammany, 996 F.2d 786, 788 (5th Cir. 1993)(citing Hardin v. Stra1ub, 490 U.S. 536, 538-39 (1989)). Although the governing period of limitations is determined by reference to state law, the accrual of a cause of action under section 1983 is determined by reference to federal law. Jackson v. Johnson, 950 F.2d 263, 265 (5th Cir. 1992). Under the federal standard, “a cause of action accrues when the plaintiff knows or has reason

to know of the injury which is the basis of the action.” Harris v. Hegmann, 198 F.3d 153, 156-57 O:\RAO\VDG\2020\20-3944.a01.wpd (5th Cir. 1999)(quoting Burrell v. Newsome, 883 F.2d 416, 418 (5th Cir. 1989)). The plaintiff must be in possession of “critical facts” which indicate that he has been hurt and that the defendants were responsible for the injury. Stewart v. Parish of Jefferson, 951 F.2d 681, 684 (5th Cir.), cert. denied, 506 U.S. 820 (1992). A plaintiff need not realize that a legal cause of action exists, but must know

the facts that would support a claim. Piotrowski v. City of Houston, 51 F.3d 512, 516 (5th Cir. 1995). The Texas period of limitations for personal injury actions is two years. See Tex. Civ. Prac. & Rem. Code Ann. § 16.003(a) (Vernon 2018). Vasquez’s claims clearly arose when he was convicted of sexual assault of a child in 1991 and failure to register as a sex offender in 2000. Vasquez did not file this suit until October 2020, almost twenty-seven years after limitations had run regarding his 1991 conviction and eighteen years after limitations had run as to his 2000 conviction. The statute of limitations bars Vasquez from asserting his civil rights claims against the named defendants. Vasquez’s claims are dismissed under 28 U.S.C. § 1915(e). Ali v. Higgs, 892

F.2d 438 (5th Cir. 1990). Alternatively, the Court finds that Vasquez’s claims are barred by the doctrine announced in Heck v. Humphrey, 512 U.S. 477, 486-87 (1994). Under Heck, the Court must dismiss a complaint brought pursuant to 42 U.S.C. § 1983, when the civil rights action, if successful, would necessarily imply the invalidity of a plaintiff’s conviction or sentence, unless the plaintiff demonstrates 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 a determination, or called into question by a federal court’s issuance of a writ of habeas corpus under 28 U.S.C. § 2254. In this instance, the crux of Vasquez’s complaint is that he was improperly charged and

convicted of sexual assault of a child and failure to register as a sex offender. The complaint O:\RAO\VDG\2020\20-3944.a01.wpd challenges his conviction based on trial court error, prosecutorial misconduct, and insufficiency of the evidence. A ruling granting Vasquez the relief which he seeks would necessarily implicate the validity of his convictions in Cause Numbers 548808 and 861633 and inevitably affect the duration of his

confinement. Under Heck, Vasquez must demonstrate that his convictions and sentences have been reversed, invalidated, or expunged prior to bringing an action under § 1983. Heck, 512 U.S. at 486-87. Vasquez cannot make such showing. He has not alleged that his convictions in Cause Numbers 548808 and 861633 have been reversed, invalidated or otherwise expunged. Until Vasquez receives a ruling declaring his sentences invalid, no action will accrue under § 1983. Id. at 488-89; Randell v.

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Related

Piotrowski v. City of Houston
51 F.3d 512 (Fifth Circuit, 1995)
Hamilton v. Lyons
74 F.3d 99 (Fifth Circuit, 1996)
McCormick v. Stalder
105 F.3d 1059 (Fifth Circuit, 1997)
Siglar v. Hightower
112 F.3d 191 (Fifth Circuit, 1997)
Harris v. Hegmann
198 F.3d 153 (Fifth Circuit, 1999)
Randell v. Johnson
227 F.3d 300 (Fifth Circuit, 2000)
Richardson v. Spurlock
260 F.3d 495 (Fifth Circuit, 2001)
Hardin v. Straub
490 U.S. 536 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bilal Muhammad Ali v. Max Higgs
892 F.2d 438 (Fifth Circuit, 1990)
Stanley J. Stewart v. Parish of Jefferson
951 F.2d 681 (Fifth Circuit, 1992)
Gerald Burge v. Parish of St. Tammany
996 F.2d 786 (Fifth Circuit, 1993)
Clarke v. Stalder
154 F.3d 186 (Fifth Circuit, 1998)

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Bluebook (online)
Vasquez v. Bunin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vasquez-v-bunin-txsd-2021.