Woodruff v. Spartanburg City Police Dep't
| Decision Date | 30 July 2018 |
| Docket Number | C/A No. 7:18-1920-BHH-JDA |
| Court | U.S. District Court — District of South Carolina |
| Parties | Stacy Danell Woodruff, Plaintiff, v. Spartanburg City Police Department, Spartanburg Herald Journal, Spartanburg County Detention Center, Nikerra Pearson-Byrd, Defendants. |
Stacy Danell Woodruff ("Plaintiff"), proceeding pro se, brings this civil action pursuant to 42 U.S.C. § 1983, alleging Defendants violated his constitutional rights. Plaintiff is a pre-trial detainee incarcerated at the Spartanburg County Detention Center, and he files this action in forma pauperis under 28 U.S.C. § 1915. The Complaint is subject to summary dismissal.
[Id. at 5-6.] Plaintiff contends that these actions violated his Fourteenth Amendment rights and that he is being falsely imprisoned. [Id. at 4.] Plaintiff alleges that, as a result of the Defendants' unlawful actions, he sustained "severe mental pain, extreme emotional distress, anxiety, humiliation and embarrassment." [Id. at 6.] For his relief, Plaintiff seeks compensation for his false imprisonment; his mental and emotional distress, anxiety, humiliation, and embarrassment; the loss of his job; and defamation of his character. [Id.] Plaintiff also seeks an apology from the Spartanburg Herald Journal. [Id.]
The Court takes judicial notice1 that Plaintiff has been charged with assault and batter of a high and aggravated nature at case number 2018A4210201860, which remains pending against him in the Spartanburg County Court of General Sessions.2
Pursuant to the provisions of 28 U.S.C. § 636(b)(1)(B), and Local Civil Rule 73.02(B)(2)(d) DSC, the undersigned is authorized to review the Complaint for relief and submit findings and recommendations to the district court. Plaintiff filed this action pursuant to 28 U.S.C. § 1915, the in forma pauperis statute. This statute authorizes the district court to dismiss a case if it is satisfied that the action "fails to state a claim on which relief may be granted," is "frivolous or malicious," or "seeks monetary relief against a defendant who is immune from such relief." 28 U.S.C. § 1915(e)(2)(B). Further, Plaintiff is a prisoner under the definition in 28 U.S.C. § 1915A(c), and "seeks redress from a governmental entity or officer or employee of a governmental entity." 28 U.S.C. § 1915A(a). Thus, even if Plaintiffhad prepaid the full filing fee, this Court is charged with screening Plaintiff's lawsuit to identify cognizable claims or to dismiss the Complaint if (1) it is frivolous, malicious, or fails to state a claim upon which relief may be granted or (2) seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A.
As a pro se litigant, Plaintiff's pleadings are accorded liberal construction and held to a less stringent standard than formal pleadings drafted by attorneys. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam). However, even under this less stringent standard, the pro se pleading remains subject to summary dismissal. The mandated liberal construction afforded to pro se pleadings means that if the Court can reasonably read the pleadings to state a valid claim on which Plaintiff could prevail, it should do so, but a district court may not rewrite a petition to include claims that were never presented, Barnett v. Hargett, 174 F.3d 1128, 1133 (10th Cir. 1999), or construct Plaintiff's legal arguments for him, Small v. Endicott, 998 F.2d 411, 417-18 (7th Cir. 1993), or "conjure up questions never squarely presented" to the Court, Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985). The requirement of liberal construction does not mean that the Court can ignore a clear failure in the pleading to allege facts which set forth a claim cognizable in a federal district court. See Weller v. Dep't of Soc. Servs., 901 F.2d 387, 391 (4th Cir. 1990).
The Complaint is filed pursuant to 42 U.S.C. § 1983, which "'is not itself a source of substantive rights,' but merely provides 'a method for vindicating federal rights elsewhere conferred.'" Albright v. Oliver, 510 U.S. 266, 271 (1994) (quoting Baker v. McCollan, 443 U.S. 137, 144 n.3 (1979)). A civil action under § 1983 "creates a private right of action to vindicate violations of 'rights, privileges, or immunities secured by the Constitution andlaws' of the United States." Rehberg v. Paulk, 132 S. Ct. 1497, 1501 (2012). To state a claim under § 1983, a plaintiff must allege two essential elements: (1) that a right secured by the Constitution or laws of the United States was violated, and (2) that the alleged violation was committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). Liberally construed, the Complaint appears to assert claims for false arrest, false imprisonment, and defamation. [See Doc. 1.] However, for the reasons below, these claims are not cognizable in this § 1983 action.
Plaintiff's claims are subject to dismissal based on the Younger abstention doctrine. Plaintiff alleges that the actions of Defendants, which resulted in his arrest and incarceration, violated his Fourteenth Amendment rights. Granting Plaintiff's requested relief would require this Court to interfere with or enjoin a pending state court criminal prosecution against Plaintiff. As such, because a federal court may not award relief that would affect pending state criminal proceedings absent extraordinary circumstances, this Court should abstain from interfering with it.
In Younger v. Harris, 401 U.S. 37 (1971), the Supreme Court held that a federal court should not equitably interfere with state criminal proceedings "except in the most narrow and extraordinary of circumstances." Gilliam v. Foster, 75 F.3d 881, 903 (4th Cir. 1996) (internal quotation marks omitted). The Younger Court noted that courts of equity should not act unless the moving party has no adequate remedy at law and will suffer irreparable injury if denied equitable relief. Younger, 401 U.S. at 43-44; see also Sprint Commc'ns, Inc. v. Jacobs, 571 U.S. 69, 72-73 (2013) ().
From Younger and its progeny, the Court of Appeals for the Fourth Circuit has culled the following test to determine when abstention is appropriate: "[1] there are ongoing state judicial proceedings; [2] the proceedings implicate important state interests; and [3] there is an adequate opportunity to raise federal claims in the state proceedings." Martin Marietta Corp. v. Md. Comm'n on Human Relations, 38 F.3d 1392, 1396 (4th Cir. 1994) (citing Middlesex Cty. Ethics Comm'n v. Garden State Bar Ass'n, 457 U.S. 423, 432 (1982)). Here, Plaintiff is involved in ongoing state criminal proceedings, and Plaintiff asks this Court to award damages and other relief for his allegedly "false" arrest and imprisonment, thus the first element is satisfied. [Doc. 1 at 6.] The second element has been addressed by the Supreme Court: "[T]he States' interest in administering their criminal justice systems free from federal interference is one of the most powerful of the considerations that should influence a court considering equitable types of relief." Kelly v. Robinson, 479 U.S. 36, 49 (1986). The Court also decided the third element in noting "that ordinarily a pending state prosecution provides the accused a fair and sufficient opportunity for vindication of federal constitutional rights." Gilliam, 75 F.3d at 903 (quoting Kugler v. Helfant, 421 U.S. 117, 124 (1975)).
Plaintiff's Complaint essentially challenges the validity of his state detention and pending criminal charges, claiming that he was falsely arrested and is being held against his will. A ruling in Plaintiff's favor in this case would call into question the validity of his arrest and would significantly interfere with Plaintiff's ongoing state criminal proceedings. See Younger, 401 U.S. at 43-45; Cinema Blue of Charlotte, Inc. v. Gilchrist, 887 F.2d 49, 52 (4th Cir. 1990) () (citation omitted); Washington v. Tilton, No. 2:10-cv-997-HFF-RSC, 2010 WL 2084383, at *1 . This Court finds that Plaintiff can raise his federal constitutional rights in the state court proceedings. Thus, this Court should abstain from hearing this action.
Heck v. Humphrey, 512 U.S. 477, 487 (1994). Plaintiff alleges that he was falsely arrested and imprisoned, and he seeks damages for the Defendant's conduct. However, Plaintiff cannot bring claims based on the alleged wrongful conduct because the Heck holding applies to this case. Plaintiff has been charged in Spartanburg County with assault and battery of a high and aggravated nature. A favorable determination on the merits of Plaintiff's § 1983 claims—i.e., a finding that Plaintiff was...
To continue reading
Request your trial