Dunbar v. Alameda Police Department

Background

Eddie Lamar Dunbar, an inmate at the Alameda County Jail, filed this case without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against state actors for violations of federal rights. He sued Alameda County; the Alameda and Oakland Police Departments; Spencer Mountain, Chris Marie, Malisha Jones, Todd Bequette, and Judge Mark Jacobson. The opinion describes the defendants as local government entities and officials and individuals involved in Dunbar’s prosecution on criminal charges.

Dunbar alleged that the defendants falsified evidence, concealed evidence favorable to him, coerced witnesses, committed perjury, engaged in malicious prosecution, and otherwise violated his rights during the prosecution. He sought money damages, dismissal of the criminal charges, and criminal charges against the defendants. The court conducted the preliminary screening required for prisoner cases seeking relief from government entities or officials.

Court’s Analysis

The court held that Dunbar’s damages claims were barred by Heck v. Humphrey. Under that rule, a person generally cannot obtain damages for conduct that would necessarily show that an existing conviction or sentence is invalid unless the conviction or sentence has been reversed, expunged, declared invalid, or called into question by a federal court’s order. The court concluded that success on Dunbar’s claims about his prosecution and trial would necessarily imply that his conviction was invalid, so those claims were not currently cognizable.

The court also held that Dunbar could not obtain dismissal of the criminal charges through this civil-rights case. A federal petition challenging the validity of a state conviction is the exclusive federal remedy for seeking release or a faster release from confinement, and such a petition could be filed only after Dunbar completed all available state-court appeals. Finally, the court stated that deciding whether to bring criminal charges against the defendants was within a prosecutor’s discretion, not the court’s authority.

Disposition

The court dismissed the case for failure to state a cognizable claim for relief. The dismissal was without prejudice to Dunbar refiling his damages claims if his conviction is later expunged, reversed, invalidated, or otherwise called into question. The court also stated that he could seek to overturn his conviction or sentence by filing a federal petition after exhausting his available state-court appeals. Judge William Alsup ordered the clerk to enter judgment and close the file.