Roberts v. City of Fairbanks, No. 18-35938 (9th Cir. 2020)
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The Ninth Circuit reversed the district court's order dismissing plaintiff's 42 U.S.C. 1983 and 1985 claims on the ground that the claims were barred by Heck v. Humphrey, 512 U.S. 477 (1994). The panel explained that whether section 1983 plaintiffs may recover damages if the convictions underlying their claims were vacated pursuant to a settlement agreement depends on whether such a vacatur serves to invalidate the convictions and thus renders the related section 1983 claims actionable notwithstanding Heck.
In this case, the panel held that all convictions underlying the section 1983 claims were vacated and no outstanding criminal judgments remained, and therefore Heck did not bar plaintiffs from seeking relief under section 1983. Accordingly, the panel remanded for further proceedings.
Court Description: Civil Rights. The panel reversed the district court’s order dismissing claims brought under 42 U.S.C. § 1983 and § 1985 on the ground that the claims were barred by Heck v. Humphrey, 512 U.S. 477 (1994), and remanded. Plaintiffs were convicted of murder but sought post- conviction relief after an individual confessed to his involvement in the murder and named other men as actual perpetrators of the crime. Pursuant to plaintiffs’ subsequent settlement agreement with prosecutors, the Alaska Superior Court vacated plaintiffs’ convictions, prosecutors dismissed all indictments, and three of the plaintiffs were released from prison. Despite a global release of all claims by plaintiffs contained in the settlement agreement, plaintiffs brought this lawsuit against the City of Fairbanks and its officers alleging, among other things, malicious prosecution and Brady violations. The district court dismissed the action without leave to amend, explaining that although the Superior Court vacated plaintiffs’ convictions pursuant to the settlement agreement and stipulation, the Superior Court did not declare the convictions invalid. The panel held that where all convictions underlying § 1983 claims are vacated and no outstanding criminal judgments remain, Heck does not bar plaintiffs from seeking relief under § 1983. The panel held that because all convictions in this case were vacated and the underlying ROBERTS V. CITY OF FAIRBANKS 3 indictments ordered dismissed, there remained no outstanding criminal judgment nor any charges pending against plaintiffs. The absence of a criminal judgment here rendered the Heck bar inapplicable; the plain language of the Supreme Court’s decision in Heck required the existence of a conviction in order for a § 1983 suit to be barred. The panel further held that the district court’s ruling to the contrary and the dissent’s proposed disposition conflicted with this Circuit’s decisions in Rosales-Martinez v. Palmer, 753 F.3d 890 (9th Cir. 2014), and Taylor v. County of Pima, 913 F.3d 930 (9th Cir. 2019). The panel rejected defendants’ argument that joinder requirements under Federal Rule of Civil Procedure 19 barred plaintiffs’ § 1983 claims because the State of Alaska was an indispensable party to this litigation. The panel held that the State of Alaska was not a necessary party here because it had not claimed any interest relating to the subject of this action, as confirmed by defendants. The panel stated that plaintiffs could obtain complete relief through their § 1983 claims against the City of Fairbanks and its officers—the alleged perpetrators of the § 1983 violations— if their action was successful. The panel considered defendants’ arguments that plaintiffs’ § 1983 claims may be dismissed based on the equitable doctrine of judicial estoppel, and that plaintiffs failed to state claims for malicious prosecution, even if not barred by Heck, because they did not allege a favorable termination. The panel held that because these arguments turned in part on the enforceability of the settlement agreement—an issue not passed upon below— the district court should be allowed to address these issues in the first instance. 4 ROBERTS V. CITY OF FAIRBANKS Dissenting, Judge Ikuta stated that plaintiffs did not have their prior convictions “declared invalid by a state tribunal authorized to make such determination,” Heck, 512 U.S. at 487, but instead reached an agreement with the state to vacate their convictions. Regardless of the plaintiffs’ reasons for doing so, they could not now claim that the prior convictions were terminated in a manner that provides a basis for bringing § 1983 malicious prosecution claims. In holding otherwise, the majority cast aside the favorable- termination rule articulated by Heck v. Humphrey and thus was inconsistent with Supreme Court precedent. ROBERTS V. CITY OF FAIRBANKS 5
The court issued a subsequent related opinion or order on June 26, 2020.
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