Brown v. City and County of San Francisco
- William Orrick
- 3:25-cv-06667
- U.S. District Court · Northern District of California
- 3
In Gregory Brown v. City and County of San Francisco, Judge Orrick dismissed Brown’s civil-rights action because Heck barred claims challenging an uninvalidated conviction or sentence.
Gregory Brown’s federal civil-rights action was dismissed, and judgment was entered in favor of the City and County of San Francisco and the individual defendants.
What happened
Gregory Brown v. City and County of San Francisco involved a lawsuit by California prisoner Gregory Brown against San Francisco officials and others. Brown alleged that the defendants violated his constitutional rights in obtaining his 1995 convictions and opposing his resentencing efforts.
The court explained that federal civil-rights claims under Section 1983 cannot proceed when winning the claims would necessarily call a conviction or sentence into question, unless that conviction or sentence has already been overturned or otherwise invalidated. Brown’s complaint did not show that his convictions or sentence had been invalidated.
Judge William H. Orrick dismissed the action under that rule. The clerk was ordered to enter judgment for the defendants and close the case; the opinion did not state that the dismissal was with or without prejudice.
The detailed version
- Brown v. City and County of San Francisco · No. 3:25-cv-06667
- William Orrick
- Dec. 9, 2025
Background
Gregory Brown, identified as a California state prisoner, is serving a sentence of 56 years to life for 1995 state convictions for conspiracy to commit murder and attempted murder. The opinion states that his appeals and resentencing petitions had been denied.
Brown filed a pro se action under 42 U.S.C. § 1983, a federal civil-rights statute that permits claims for violations of federal rights by people acting under state law. He sued the City and County of San Francisco; Floyd Andrews; Allison Macbeth; Alex Berstein; Claudia Phillips; Brooke Jenkins; and Rob Bonta. The opinion identifies several of the individual defendants by their prosecutorial or governmental positions. Brown alleged that the defendants violated his federal constitutional rights in securing his convictions and in opposing his efforts to overturn or reduce his convictions and sentence.
Court’s analysis
The court reviewed the complaint under 28 U.S.C. § 1915(e), which requires screening of the complaint and dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money from a defendant who is immune from that relief. The court also noted that it must read a self-represented litigant’s pleadings liberally, while requiring enough factual matter to state a plausible claim.
The court applied the rule from Heck v. Humphrey. Under that rule, a prisoner generally cannot seek damages under Section 1983 when success would necessarily imply that the prisoner’s conviction or sentence is invalid, unless the conviction or sentence has already been reversed on appeal, expunged, declared invalid by an authorized state tribunal, or called into question by a federal court’s issuance of a writ of habeas corpus.
The court concluded that a judgment in Brown’s favor on his allegations concerning the convictions and sentence would necessarily imply that they were invalid. The complaint did not indicate that the convictions or sentence had been invalidated in one of the ways recognized by Heck. The court therefore held that the action was barred by Heck.
Disposition
The court DISMISSED the federal civil-rights action. It directed the clerk to enter judgment in favor of the defendants and close the file. The opinion states that the filing fee had been paid. It does not specify that the dismissal was with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.