Walker v. Kansas, State of

District Court, D. Kansas·Decided October 9, 2025·No. 5:25-cv-03158·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

EARNEST EUGENE WALKER, JR.,

Plaintiff,

v. CASE NO. 25-3158-JWL

STATE OF KANSAS, et al.,

Defendants.

MEMORANDUM AND ORDER

On August 11, 2025, Plaintiff and state prisoner Earnest Eugene Walker, Jr. filed this pro se civil action pursuant to 42 U.S.C. § 1983. (Doc. 1.) He was granted leave to proceed in forma pauperis (Doc. 3) and has paid the filing fee in full. This matter comes now before the Court on Plaintiff’s motion for appointment of counsel (Doc. 6) and his amended complaint (Doc. 7). For the reasons set forth in this order, this matter will be dismissed and the motion for appointment of counsel will be denied. I. Background This case concerns two criminal cases in Sedgwick County, Kansas in which Plaintiff was the defendant—Case No. 91cr89812, which will be referred to in this order as the 1991 case, and Case No. 93CR1193, which will be referred to in this order as the 1993 case. (Doc. 1, p. 2.) In February 1992, Plaintiff was sentenced to probation in the 1991 case and he was later sentenced in the 1993 case to an indeterminate 1- to 5-year prison sentence, to run concurrently to the probation. Id. In March 1998, Plaintiff’s probation was revoked and he was ordered to serve the prison sentence. Id. Plaintiff now asserts that his term of probation had either been completed or had expired prior to revocation. (Doc. 7, p. 2.) Plaintiff filed his initial complaint seeking relief under 42 U.S.C. § 1983 on August 11, 2025. (Doc. 1.) Because Plaintiff is a prisoner and proceeds in forma pauperis, the Court was required by statute to screen his complaint and to dismiss it or any portion thereof that is frivolous, fails to state a claim on which relief may be granted, or seeks relief from a defendant immune from such relief. 28 U.S.C. § 1915A(a) and (b); 28 U.S.C. § 1915(e)(2)(B). The Court conducted the required

screening of the complaint and, on September 10, 2025, issued a memorandum and order (“M&O”) identifying deficiencies in the complaint that left it subject to dismissal in its entirety. (Doc. 5.) The M&O first stated that it was not clear who Plaintiff intended to name as Defendants in this matter and, to the extent Defendants could be identified, they were not proper Defendants to a suit brought under § 1983 or they were immune from Plaintiff’s claims. Id. at 1-2, 4-8. Second, the M&O explained that Count I, which alleged the violation of the Thirteenth Amendment and characterized Plaintiff’s prison sentence as a term of involuntary servitude, failed to state a plausible claim for relief. Id. at 8-9; see also Ruark v. Solano, 928 F.2d 947, 949-50 (10th Cir. 1991) (“[T]he thirteenth amendment’s restriction on involuntary servitude does not apply to

prisoners.”), overruled on other grounds by Lewis v. Casey, 518 U.S. 343 (1996). The complaint also alleged that Plaintiff’s due process and equal protection rights under the Fourteenth Amendment were violated (Count II), that he received ineffective assistance of counsel in violation of the Sixth Amendment (Count IV), and that he suffered cruel and unusual punishment in violation of the Eighth Amendment (Count V). The M&O explained that the lack of specific factual allegations supporting those claims left them subject to dismissal for failure to state a plausible claim for relief. (Doc. 5, p. 9-10.) The M&O next briefly reminded Plaintiff that “violations of state law do not provide an independent basis for relief under § 1983” and explained that in Heck v. Humphrey, 512 U.S. 477 (1994), the United States Supreme Court “‘held that prisoners may not bring a § 1983 action that calls into question the lawfulness of their [state] conviction until the conviction has been invalidated.” (Doc. 5, p. 10 (quoting Johnson v. Spencer, 950 F.3d 680, 692 (10th Cir. 2020).) In addition to Count I of the complaint, which argued that Plaintiff’s prison sentence was involuntary servitude, Count III alleged that Plaintiff’s Fifth Amendment rights were violated when his

probation was revoked, and Count IV alleged the ineffective assistance of counsel during state- court proceedings. The M&O explained that Heck appears to bar the claims in Counts I, III, and IV. (Doc. 5, p. 10-11.) Because all five counts alleged in the complaint were subject to dismissal, the Court granted Plaintiff time in which to file a complete and proper amended complaint that cures the deficiencies identified in the M&O. Id. at 11. Plaintiff has timely filed his amended complaint. (Doc. 7.) Therefore, as stated in the M&O, “the Court will conduct the statutorily required review of the amended complaint.” (See Doc. 5, p. 12.) II. The Amended Complaint (Doc. 7)

In the amended complaint, Plaintiff names as Defendants: the State of Kansas; Christian E. Zoller and Pamela C. Parker, two attorneys appointed to represent Plaintiff in state-court proceedings; Kurt Kearns, “who [Plaintiff] paid $500 to look into [Plaintiff’s] illegal sentence [in] 1998”; Dawn L. Helmer, who in 1998 was a Community Corrections Officer; Mona C. Furst, who in 1998 was a prosecutor in Sedgwick County, Kansas; C. Robert Bell, the state judge who revoked Plaintiff’s probation and ordered him to serve the prison sentence; Correctional Officer Needham, who worked at Lansing Correctional Facility in 2007; and two John Doe Correctional Officers who worked at Norton Correctional Facility on unknown dates. (Doc. 7, p. 1-4.) Plaintiff purports to sue each Defendant in his or her individual and official capacities. Id. at 4. The amended complaint contains five counts. In Count I, Plaintiff again asserts the violation of the Thirteenth Amendment’s prohibition of involuntary servitude. Id. at 5. As supporting facts for Count I, he asserts that revoking his probation in 1998 violated K.S.A. 21- 6608 and “those who were present and in authority” should have known thar revoking his probation and ordering him to serve prison time was illegal. Id. In Count II, Plaintiff again asserts

the violation of his Fourteenth Amendment rights to due process and equal protection of the laws. Id. As supporting facts for Count II, Plaintiff states that he “should never have been sent to prison if not for the malicious intent of his probation officer or the incompetence of his attorney[,] the Judge or Prosecutor unless their intent was malicious.” Id. In Count III, Plaintiff again asserts the violation of the Fifth Amendment’s prohibition of double jeopardy and its guarantee of due process. Id. at 6. As supporting facts for Count III, Plaintiff argues that he had served his probation term in full, but he also acknowledges that he failed to pay court costs and restitution as ordered. Id. Plaintiff argues that instead of ordering him to serve prison time, the matter “should have been turned over to collections.” Id. In Count IV,

Plaintiff again asserts the violation of his Sixth Amendment right to the effective assistance of counsel. Id. at 7.

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Related

Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Fogle v. Pierson
435 F.3d 1252 (Tenth Circuit, 2006)
Johnson v. Spencer
950 F.3d 680 (Tenth Circuit, 2020)