Jackson v. Tafla
- Edward Davila
- 5:20-cv-06766
- U.S. District Court · Northern District of California
- 3
In Jackson v. Tafla, Judge Davila dismissed Jackson’s damages case without prejudice because his conviction was not shown invalid and denied withdrawal as moot.
Walter Jackson, whose damages action was dismissed without prejudice; the two individual defendants and the Contra Costa County Criminalistics Laboratory named in his allegations; and Jackson’s motion to withdraw, which was denied as moot.
What happened
Jackson v. Tafla involved Walter Jackson’s unrepresented civil-rights lawsuit seeking damages for an allegedly unconstitutional conviction. Jackson alleged that two individuals and the Contra Costa County Criminalistics Laboratory failed to test material collected during an autopsy, leaving potentially relevant results unavailable at his criminal trial. He claimed he was falsely convicted and sought $1,000 per day for his incarceration.
The court said a person cannot use this type of civil-rights lawsuit to seek damages for a conviction that has not been overturned, invalidated, or otherwise called into question. Jackson remained incarcerated and had not shown that his conviction had been invalidated. The court said he could instead seek relief from the conviction through a separate federal petition challenging his imprisonment.
Judge Davila dismissed the action without prejudice as barred by that rule and denied Jackson’s motion to withdraw the lawsuit as moot. The clerk was directed to send Jackson two copies of the court’s petition form, and the order terminated the motion docketed as No. 8.
The detailed version
- Jackson v. Tafla · No. 5:20-cv-06766
- Edward Davila
- Feb. 11, 2021
Background
Walter Jackson, a state prisoner proceeding without a lawyer, filed a civil-rights action seeking damages for an allegedly unconstitutional conviction from Contra Costa County. He alleged that two individuals and the Contra Costa County Criminalistics Laboratory failed to test “air-way material during autopsy” to determine the cause of death, so the results were not available during his criminal trial. Jackson claimed that he was falsely convicted and slandered, and sought damages of $1,000 per day for his alleged wrongful incarceration.
The court noted that Jackson’s request to proceed without paying the filing fee would be addressed in a separate order. Because a prisoner sued governmental entities or personnel, the court conducted the preliminary screening required by 28 U.S.C. § 1915A. The court also explained that a claim under 42 U.S.C. § 1983, the federal civil-rights statute, requires an alleged violation of a constitutional or federal right by someone acting under state authority.
Analysis
The court applied the rule from Heck v. Humphrey. Under that rule, a § 1983 plaintiff cannot obtain damages for an allegedly unconstitutional conviction or imprisonment, or for conduct that would necessarily make the conviction or sentence invalid, unless the conviction or sentence has already been reversed, expunged, declared invalid, or called into question by a federal court’s order granting a petition challenging the imprisonment.
Jackson remained incarcerated and had not shown that his conviction had been invalidated. The court therefore concluded that his damages claim was not permitted under § 1983. It further explained that a civil-rights complaint seeking release from or other relief concerning a conviction should be brought as a petition under 28 U.S.C. § 2254, rather than as a § 1983 action.
Disposition
Judge Edward J. Davila ordered that the action be dismissed without prejudice as barred by Heck. The court denied as moot Jackson’s motion to withdraw the lawsuit. The clerk was directed to send Jackson two copies of the court’s petition form with the order, and the order terminated Docket No. 8.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.