Byrd v. Phoenix Police Department, No. 16-16152 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit reversed the district court's sua sponte dismissal of a complaint seeking damages under 42 U.S.C. 1983 for alleged violations of plaintiff's constitutional rights by police officers during a traffic stop. The panel disagreed with the district court that plaintiff's allegation that the officers "beat the crap out of" him was too vague and conclusory to support a legally cognizable claim. The panel explained that plaintiff's use of a colloquial, shorthand phrase makes plain that plaintiff was alleging that the officers' use of force was unreasonably excessive. The panel also held that Heck v. Humphrey, 512 U.S. 477 (1994), did not bar plaintiff's other claims.
Court Description: Prisoner Civil Rights The panel reversed the district court’s sua sponte dismissal of a complaint seeking damages under 42 U.S.C. § 1983 for alleged violations of plaintiff’s constitutional rights by Phoenix police officers during a traffic stop. The panel disagreed with the district court that the allegation that the officers “beat the crap out of” plaintiff was too vague and conclusory to support a legally cognizable claim. The panel held that plaintiff’s use of a colloquial, shorthand phrase made plain that he was alleging that the officers’ use of force was unreasonably excessive; this conclusion was reinforced by his allegations about the resulting injuries. The panel held that plaintiff’s § 1983 claims alleging Fourth Amendment and due process violations were not barred by Heck v. Humphrey, 512 U.S. 477 (1994), which held that § 1983 claims are not cognizable if a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence. The panel noted that plaintiff pleaded guilty to conspiracy to commit possession of a dangerous drug for sale, that no evidence was produced against him at his plea hearing, and that he alleged no facts
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