Abdul-Matiyn v. District Attorney's Office Bronx County

Background

Faris Abdul-Matiyn, proceeding without a lawyer, filed a claim under 42 U.S.C. § 1983 against the Bronx County District Attorney’s Office. He alleged that the office deprived him of a fair trial by conspiring against him because he is Black and would not plead guilty, using false testimony about the layout of his apartment, relying on testimony about a nonexistent bloody machete, and causing his attorney to disclose privileged information. He sought a declaration that these actions violated his constitutional rights and that his conviction was obtained through false testimony.

The complaint did not provide details about the conviction, including when, where, or for what offenses he was convicted. The court reviewed public records stating that he was convicted after a 1984 jury trial, received prison sentences, was released on parole in 2006, and was discharged from parole in 2008. The court also noted that his prior appeals and a federal challenge to the conviction had been denied.

Legal standards

Because Abdul-Matiyn had been allowed to file without paying the filing fee, the court was required to dismiss the complaint if it was frivolous, failed to state a legally sufficient claim, sought relief from an immune defendant, or presented no subject-matter jurisdiction. A complaint must include enough factual allegations to make the claimed violation plausible, although courts must read filings by people without lawyers liberally.

A § 1983 claim requires a violation of a federal constitutional or statutory right by a person acting under state authority. Prosecutors generally have absolute immunity from civil damages claims for conduct closely connected to the judicial phase of a criminal case. State agencies and state officials acting as state agents also generally have Eleventh Amendment immunity from federal claims for damages, injunctive relief, and declarations about past violations. Prospective relief addressing an ongoing violation may sometimes avoid those protections.

Court’s analysis

The court determined that Abdul-Matiyn could not be seeking prospective relief because the criminal case underlying his complaint had ended, he had completed his prison sentence, and he had been discharged from parole. His request for a declaration that the defendants violated his rights during the 1984 trial sought only recognition of an alleged past wrong. The court concluded that this did not present the ongoing dispute required for declaratory relief.

The court further concluded that the § 1983 claims were barred by prosecutorial immunity and the Eleventh Amendment. It therefore dismissed the claims without reaching whether the alleged false testimony, disclosure of information, or other conduct actually violated Abdul-Matiyn’s constitutional rights.

Disposition

Chief United States District Judge Laura Taylor Swain dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(iii). The court declined to grant leave to amend because it found that the defects could not be cured by amendment. It also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied fee-waiver status for purposes of an appeal.