Washington-Steele v. City of New York

Background

Zahmeil D. Washington-Steele proceeded without a lawyer and sued the City of New York and Detective Paul Scott under 42 U.S.C. § 1983, a federal law allowing claims for certain constitutional violations by state or local officials. He alleged false arrest and malicious prosecution. He claimed that police took him from his home on October 3, 2017, held and questioned him for more than 12 hours, and placed him in an identification lineup in connection with a recent stabbing.

Washington-Steele was later indicted for attempted murder and first-degree robbery. On May 23, 2019, he was convicted after a jury trial of attempted murder in the first degree and first-degree robbery. The opinion states that the convictions had not been reversed, expunged, declared invalid, or otherwise called into question by a federal court.

Motion to dismiss

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. The court accepted the complaint’s factual allegations as true for purposes of the motion and read the pro se complaint liberally, but explained that it still had to state a plausible claim for relief.

Section 1983 claims

The court held that both claims were barred by the rule from Heck v. Humphrey. That rule generally prevents a person from seeking damages under § 1983 for conduct that, if proved unlawful, would call an existing criminal conviction or sentence into question unless the conviction or sentence has already been invalidated in one of the ways recognized by law.

The court concluded that Washington-Steele’s false-arrest and malicious-prosecution claims arose from the offenses for which he was convicted and would imply that his convictions were invalid. Because the convictions remained valid, the court held that Heck barred the claims. The court also stated that the valid convictions supplied evidence of probable cause for the arrest and prosecution, and that a malicious-prosecution claim requires the criminal case to end in the plaintiff’s favor.

State-law claims and other requests

The court found that the complaint did not assert state-law claims against the City or Detective Scott. It therefore did not decide whether such claims would be timely or whether it should exercise supplemental jurisdiction over them. The court stated that any state-law claims should be brought in state court. The opinion also records that Washington-Steele’s request for oral argument was denied; his earlier request for appointed counsel had also been denied.

Disposition

The court granted the defendants’ motion to dismiss, without prejudice, and directed the Clerk of Court to terminate the motion and close the case.