Godfrey v. Trujillo

Background

Ricky Godfrey sued Dennis Trujillo, Denis Browne, the Estate of Denis Browne, and the City of Richmond, California, under 42 U.S.C. § 1983, a federal law allowing claims for constitutional violations by officials acting under state law. Godfrey’s claims concern alleged misconduct in the investigation leading to his original 1993 conviction.

On August 18, 2025, the court granted in part and denied in part defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The court dismissed Godfrey’s claim against the City of Richmond under the rule associated with municipal liability, commonly called a Monell claim, but allowed his remaining § 1983 claims against Trujillo and Browne to proceed.

Defendants then moved under 28 U.S.C. § 1292(b) to certify an interlocutory appeal. An interlocutory appeal is an appeal before the district court has entered a final judgment. Defendants also asked the court to stay, or pause, the case while any appeal was resolved.

Arguments and analysis

Defendants proposed an appeal concerning whether Heck v. Humphrey barred Godfrey’s claims. Heck generally prevents a person from recovering damages for unconstitutional imprisonment when success would undermine an existing conviction, unless the conviction has been declared invalid by an authorized state tribunal.

Defendants argued that Heck still barred the claims because Godfrey’s 1993 convictions were vacated for reasons unrelated to the alleged police misconduct. They also argued that success on the § 1983 claims would necessarily contradict factual admissions underlying Godfrey’s 2023 no-contest plea to voluntary manslaughter and attempted robbery.

The court held that defendants had not shown a substantial ground for disagreement about the effect of Heck. It rejected defendants’ proposed requirement that the earlier conviction must have been invalidated specifically because of the constitutional violations later alleged in the § 1983 case. The court relied on decisions stating that convictions invalidated for other reasons can satisfy Heck’s requirement that the conviction have been declared invalid.

The court also rejected defendants’ argument about the 2023 plea. It explained that Godfrey’s § 1983 claims concern whether investigative methods used in 1992 were constitutional and do not require him to prove that he was innocent of the death or attempted robbery. A finding that Trujillo or Browne fabricated evidence or violated disclosure duties would concern the vacated 1993 conviction, not the factual admissions underlying the still-valid 2023 conviction.

The court distinguished a Ninth Circuit case in which a civil-rights claim was barred because success would have contradicted the plaintiff’s no-contest admission that police had used lawful force. The court concluded that no comparable contradiction would result here.

Ruling

Judge Araceli Martinez-Olguin denied defendants’ motion to certify an interlocutory appeal and denied their motion to stay the case. The order terminated Docket No. 37.