Turner v. Contra Costa County Supreme Court

Background

Curtis Turner filed a self-represented civil-rights action under 42 U.S.C. § 1983 while confined at West County Detention Facility. He sought a settlement and an award in his favor. His allegations concerned state criminal proceedings in Contra Costa County Superior Court, including charges of indecent exposure, carrying a dirk or dagger, and violating probation.

Turner alleged a “court conspiracy,” ineffective assistance of counsel, attorney malpractice, and other misconduct. He stated that two evaluations found him competent, while a third evaluation by one of the same doctors found him incompetent. He alleged that false claims were made against him and that the court found him incompetent and scheduled him for a Department of State Hospitals commitment. He named his public defender, the district attorney, the trial judge, and people who worked for the Contra Costa County Supreme Court and public defender’s office.

The court understood Turner to be challenging the finding that he was incompetent to stand trial under California Penal Code § 1370. The complaint also included a claim for compassionate release under California Penal Code § 1370.015. The court reviewed state-court docket information and concluded that state proceedings appeared to be ongoing or restarting, including a mental-health-diversion petition and several scheduled hearings.

Screening and legal analysis

Because Turner was a prisoner suing governmental entities or officials, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court had to identify claims that were legally viable and dismiss claims that were frivolous, failed to state a claim, or sought money from an immune defendant. The court also stated that it had to read self-represented pleadings liberally.

The court explained that a § 1983 claim requires allegations that a federal constitutional or statutory right was violated and that the violation was committed by someone acting under state authority.

The court concluded that damages claims against the trial judge were barred by absolute judicial immunity because finding Turner incompetent to stand trial was a judicial act. The damages claim against the prosecuting attorney was also barred by absolute prosecutorial immunity for conduct connected with pursuing a criminal prosecution. The court further held that Turner could not state a § 1983 claim against his public defender for performing traditional defense-lawyer functions because the public defender was not acting under state authority in that role.

For any remaining claims, the court applied the rule from Heck v. Humphrey. Under that rule, a person generally cannot obtain damages under § 1983 for an allegedly unconstitutional conviction, sentence, or related commitment when success would necessarily imply that the conviction, sentence, or commitment is invalid, unless it has already been overturned, expunged, declared invalid, or called into question by a federal court’s issuance of a writ of habeas corpus. The court stated that this rule applied here because Turner appeared to have been found incompetent to stand trial and success on his damages claim would necessarily imply that his civil commitment was invalid.

Guardian ad litem

Federal Rule of Civil Procedure 17(c) addresses protection of minors and incompetent persons who lack an appointed representative. The court explained that appointment of a guardian ad litem for a self-represented litigant who is incompetent is not mandatory in every case. Because Turner had no viable claim at that point and could potentially return with a § 1983 claim if the underlying commitment, sentence, or conviction were invalidated, the court declined to assess his competence or appoint a guardian ad litem at that time.

Disposition

Judge Beth Labson Freeman ordered that the complaint be dismissed without prejudice as barred by Heck. The court stated that Turner could potentially bring a § 1983 claim if the underlying commitment, sentence, or conviction were later reversed on direct appeal, expunged by executive order, declared invalid by an authorized state tribunal, or called into question by a federal court’s issuance of a writ of habeas corpus. The court also stated that Turner’s motion to proceed without paying the filing fee would be granted in a separate order.