Heller v. Marin County Public Defender's Office
- William Orrick
- 3:23-cv-05585
- U.S. District Court · Northern District of California
- 1
In Heller v. Marin County Public Defender’s Office, Judge Orrick dismissed Heller’s civil-rights suit because public defenders are not state actors when defending clients.
Mark Anthony Heller’s claims against his public defenders and the Marin County Public Defender’s Office were dismissed; judgment was entered in favor of the defendants.
What happened
Heller v. Marin County Public Defender’s Office concerns Mark Anthony Heller’s claims that his public defenders and the Marin County Public Defender’s Office mishandled his criminal defense.
Heller brought a lawsuit under a federal civil-rights law that allows claims against people acting for a state. The court reviewed the complaint under the statute requiring early screening of certain prisoner lawsuits.
Judge William H. Orrick dismissed the suit because public defenders do not act for the state, in the legal sense required by that civil-rights law, when performing traditional defense-lawyer duties. The court ordered judgment for the defendants and closed the case.
The detailed version
- Heller v. Marin County Public Defender's Office · No. 3:23-cv-05585
- William Orrick
- Dec. 1, 2023
Background
Mark Anthony Heller sued his public defenders and the Marin County Public Defender’s Office, alleging that they mishandled his criminal defense. His complaint invoked 42 U.S.C. § 1983, a federal law that permits civil-rights claims against people acting under state authority. The court reviewed the complaint under 28 U.S.C. § 1915A(a), which requires screening of qualifying complaints at an early stage.
Court’s reasoning
The court held that public defenders do not act “under color of state law”—an essential requirement for a § 1983 claim—when performing their traditional functions as defense lawyers. Relying on Polk County v. Dodson, the court concluded that a § 1983 suit against public defenders based on those lawyerly functions could not proceed.
Disposition
The court dismissed the suit. It directed the Clerk to enter judgment in favor of the defendants and close the file. The opinion does not state that the dismissal was with or without prejudice.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.