Wright v. Contra Costa Country

Background

Michael Wright, an inmate at San Quentin State Prison, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983. The court screened his complaint under 28 U.S.C. § 1915A, which requires an early review of a prisoner’s claims against a governmental entity or its officers or employees. The court stated that it must dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. Wright’s request to proceed without paying the filing fee had been granted in a separate order.

Wright was serving a criminal conviction and sentence from Contra Costa County Superior Court for multiple sex offenses involving a child. A state appeals court reversed convictions on counts 3, 4, and 10 because the evidence was sufficient to show that the charged acts occurred but insufficient to establish the victim’s age as required for those counts. The state appeals court affirmed the judgment in all other respects and sent the case back for resentencing consistent with its decision.

Claims and Defendants

Wright sued Contra Costa County; District Attorney Diana Becton; District Attorney Mark Petterson; and Assistant District Attorney Bell. He alleged that Bell presented insufficient evidence, used testimonial hearsay in violation of the constitutional rule discussed in Crawford, presented prejudicial and inadmissible bad-character evidence, made improper arguments about that evidence and hearsay, and misstated facts and law during closing argument. He also alleged that his sentence was substantially disproportionate under the Eighth Amendment’s ban on cruel and unusual punishment.

Wright asserted supervisory-liability claims against Becton and Petterson and a municipal-liability claim against Contra Costa County. He sought $15 million in compensatory damages and $15 million in punitive damages from each defendant, as well as costs and other relief.

Court’s Analysis

The court applied Heck v. Humphrey, which generally bars a § 1983 action when success would necessarily imply that a conviction or sentence is invalid and that conviction or sentence has not been invalidated. The court explained that only counts 3, 4, and 10 had been invalidated, and only as to the victim’s age. The remaining counts had been affirmed. Therefore, to the extent Wright’s claims challenged counts that remained valid, the court held that Heck barred them. The court also stated that Wright’s challenges concerned the validity of his confinement and therefore belonged in a petition challenging the conviction or custody, rather than in a § 1983 action.

The court separately addressed claims related to counts 3, 4, and 10. It stated that Bell was protected by absolute prosecutorial immunity for conduct involved in pursuing a criminal prosecution and presenting the government’s case. The court further held that Becton and Petterson could not be held liable merely because they were supervisors, because § 1983 does not impose liability solely through a supervisor’s role. The municipal-liability claim against Contra Costa County failed because the court found that Bell, Becton, and Petterson had not violated Wright’s constitutional rights. The court also stated that a municipality may be liable under § 1983 only in circumstances involving an official policy, a longstanding practice or custom, or a decision by a final policymaker.

Disposition

The court dismissed the action with prejudice for failure to state a claim. It explained that amendment would be futile, so it denied leave to amend. The clerk was directed to issue judgment and close the file.

Terminology note

The opinion describes Bell’s immunity as prosecutorial immunity in its main Heck discussion and later refers to judicial immunity when discussing the same claims. This summary reports both formulations rather than resolving that inconsistency.