France v. Lunceford
- William Alsup
- 3:19-cv-03934
- U.S. District Court · Northern District of California
- 4
In France v. Lunceford, Judge Alsup granted defendants’ summary-judgment motions and denied reconsideration because the claims were barred while the conviction stood.
Michael Ray France’s federal civil-rights claims against Ross Lunceford, Chris Dewey, David Eyster, and the City of Ukiah could not proceed while his conviction remained valid. The defendants obtained summary judgment, and the case was closed.
What happened
In France v. Lunceford, Michael Ray France, a California state prisoner representing himself, claimed that an officer and prosecutor lied about the basis for a warrantless house search and falsified a police report. He brought the claims under a federal civil-rights law, and the defendants moved for summary judgment, which asks whether the evidence requires a trial.
The court held that these claims repeated claims from France’s earlier lawsuit involving the search, arrest, and prosecution. Under a rule from Heck v. Humphrey, a prisoner generally cannot pursue civil-rights claims that would necessarily undermine an existing conviction. The court concluded that proving the alleged lies would invalidate the search, the gun evidence, and France’s conviction, so the defendants were entitled to summary judgment.
Judge William Alsup granted the defendants’ motions for summary judgment, denied France’s motion for reconsideration concerning discovery and more time to respond, and directed the clerk to enter judgment and close the file.
The detailed version
- France v. Lunceford · No. 3:19-cv-03934
- William Alsup
- June 29, 2020
Background
Michael Ray France, a California state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983. He alleged that Ross Lunceford, the arresting Ukiah police officer, lied during a state-court suppression hearing and in a police report. The alleged lie concerned whether Lunceford believed that a probationer, Jarod Kidd, was at the house where France was staying and whether that belief permitted a warrantless search. The search uncovered France’s gun. France also alleged that District Attorney David Eyster knew Kidd was incarcerated at the time. The defendants included Lunceford, Chris Dewey, David Eyster, and the City of Ukiah.
The City of Ukiah and Lunceford filed one motion for summary judgment, and Eyster filed another. France did not oppose the motions despite receiving two extensions of time and a warning about the consequences of failing to respond.
Analysis
The court explained that France had raised the same factual allegations in an earlier related proceeding, docket number C 19-5969 WHA (PR). In that earlier proceeding, he asserted claims involving an illegal search, false arrest, and malicious prosecution. Those claims had been dismissed under Heck v. Humphrey because proving them would necessarily undermine the validity of his conviction for being a felon in possession of a gun.
France argued that this case involved different claims—perjury at the suppression hearing and falsification of the police report. The court rejected that distinction. It held that the alleged perjury and report falsification were not independent claims because France would need to prove the same alleged lie to establish that the search, arrest, and prosecution were unconstitutional. The court further held that proving the lie would necessarily mean that the search was illegal, admitting the gun into evidence was erroneous, and France’s conviction was invalid. Under Heck, France could not pursue those claims in a federal civil-rights action while the conviction remained valid.
Other Motion and Disposition
France also sought reconsideration of an earlier order denying his requests for discovery and a third extension of time to oppose summary judgment. The court denied reconsideration. It stated that the defendants’ arguments were legal arguments that did not require discovery, that France had already received two extensions and four months to respond, and that his explanation concerning COVID-19-related prison restrictions did not account for his failure to respond during the earlier period.
Judge William Alsup granted the defendants’ motions for summary judgment and denied the motion for reconsideration. The clerk was directed to enter judgment and close the file. The opinion also states that the claims had previously been dismissed without prejudice to a new civil-rights action if the conviction were reversed, dismissed, expunged, or otherwise invalidated; it does not state that the summary-judgment ruling itself used that phrase.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.