Turner v. Castellanos

Background

Vincent Rene Turner, an inmate at Mule Creek State Prison, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983. The court reviewed the complaint under the federal statute requiring early screening of prisoner lawsuits against governmental entities or their officers and employees. Turner had separately been allowed to proceed without prepaying the filing fee.

Turner named Judge Cecilia Castellanos and Deputy District Attorney Sharon Carney as defendants. He alleged that Carney withheld exculpatory evidence—evidence potentially favorable to the defense—and produced it only after Turner was convicted. He alleged that Judge Castellanos knew about the evidence but allowed Carney to withhold it. Turner sought $60 million in damages.

Court’s analysis

The court applied the rule established in Heck v. Humphrey. Under that rule, a person generally cannot recover damages under § 1983 for conduct whose unlawfulness would necessarily make the person’s conviction or sentence invalid unless the conviction or sentence has already been reversed on appeal, nullified by executive action, declared invalid by an authorized state tribunal, or called into question by a federal court’s issuance of an order granting release from unlawful custody.

The court concluded that a successful § 1983 claim based on withholding exculpatory evidence would necessarily imply that Turner’s conviction was invalid. Because the complaint did not establish that the conviction had already been invalidated, the court held that the claim was not allowed under § 1983 and dismissed the action as barred by Heck.

In a footnote, the court stated that Turner’s claims were also likely barred by judicial immunity and prosecutorial immunity. Those legal protections can shield judges and prosecutors from damages claims for conduct within their protected judicial or prosecutorial roles. The court did not identify those immunities as the stated basis of its dismissal; its conclusion and order relied on the Heck bar.

Disposition

The court DISMISSED the action as barred by Heck. It directed the Clerk to enter judgment in favor of the defendants and close the file. The opinion does not state whether Turner’s conviction had been overturned or otherwise invalidated beyond explaining that the complaint did not make the claim cognizable under § 1983.

Judge Jon Tigar issued and signed the order on April 21, 2020.