Graham v. Nelson

Background

William Charles Graham filed this civil action without a lawyer while confined at the Sherburne County Jail in Elk River, Minnesota. He sued United States District Judge Susan R. Nelson, Magistrate Judge Katherine M. Menendez, United States Attorney Erica H. MacDonald, Assistant United States Attorneys Amber M. Brennan and Justin A. Wesley, and Federal Defender Andrew H. Mohring. He brought the case under federal-question jurisdiction and a claim recognized under Bivens, which can allow damages claims against certain federal officials for constitutional violations.

Graham alleged that the United States Marshals transferred him from Hennepin County without a writ, that an indictment document was defective or improperly presented, and that his not-guilty plea was entered without his consent. He also alleged that the court lacked authority and jurisdiction, that he was unlawfully detained, and that the defendants interfered with his family relationship and caused financial, emotional, mental, and physical harm. He cited the First, Fourth, Fifth, Sixth, Eighth, Ninth, Tenth, Eleventh, Thirteenth, and Fourteenth Amendments. He asked the court to dismiss the charging document in his pending criminal case or award other relief.

Screening standard

Because Graham asked to proceed without prepaying court fees, the court screened the complaint under 28 U.S.C. § 1915. That statute requires dismissal at any time if the action is legally frivolous, fails to state a claim on which relief may be granted, or seeks money from a defendant who is immune from such relief. The court described a legally frivolous action as one lacking an arguable basis in law or fact.

Court’s analysis

The court noted that Graham’s criminal case remained pending and that a jury trial was scheduled for April 20, 2020. To the extent Graham sought release from custody or dismissal of the charging document, the court held that this relief was not available in the present civil action because a custody challenge seeking immediate or faster release must be brought through the specific legal process for challenging confinement.

For any other relief, the court applied the rule from Heck v. Humphrey. Under that rule, a civil-rights claim cannot proceed when winning it would necessarily show that a conviction or sentence is invalid, unless the conviction or sentence has already been overturned or otherwise invalidated. The court stated that the same rule applies to Bivens actions and to claims that would necessarily undermine a pending criminal charge. It concluded that a judgment for Graham would necessarily imply that his pending federal criminal proceedings were invalid.

Disposition

The court held that Graham’s claims were legally frivolous and failed to state a claim on which relief could be granted. It therefore ordered that his request to proceed without prepaying court fees was granted, and that the case was summarily dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B)(i)–(iii). The order also provided information about appellate filing-fee obligations if Graham appealed.