Chad William Reed V Mark D Uptegrove Et Al

Key Facts

Issues

• Whether Plaintiff Chad William Reed stated cognizable claims under 42 U.S.C. § 1983 against McCurtain County District Attorney Mark Matloff for alleged Napue violations, Brady violations, retaliation, and cruel and unusual punishment, and whether such claims are barred by the Heck doctrine or time-barred.
• Whether Plaintiff Chad William Reed stated a cognizable claim under 42 U.S.C. § 1983 against McCurtain County District Judge Emily Maxwell and Special Judge Mark Uptegrove arising from his unsuccessful post-conviction relief applications, including whether claims are barred by the Heck doctrine, Rooker-Feldman doctrine, or judicial immunity.
• Whether Special Judge Mark Uptegrove is entitled to absolute judicial immunity from suit for civil damages for acts made in the exercise of judicial discretion when ruling on Reed's application for post-conviction relief.
• Whether Plaintiff Reed's Section 1983 claims seeking damages, declaratory relief, or injunctive relief against the Judicial Defendants and District Attorney are barred by Heck v. Humphrey because the claims would necessarily imply the invalidity of Reed's state conviction or sentence.
• Whether the federal district court has jurisdiction to hear Plaintiff Reed's claims challenging the denial of his post-conviction relief application by Special Judge Uptegrove under the Rooker-Feldman doctrine, which bars federal courts from reviewing state-court judgments.

Holdings

• The court grants Defendant McCurtain County District Attorney Mark Matloff's Motion to Dismiss. Reed's Napue and Brady claims are barred by Heck v. Humphrey because successful claims would imply invalidity of conviction. The retaliation claim is time-barred as it occurred in 2006 and Oklahoma's two-year statute of limitations has expired. The Eighth Amendment cruel and unusual punishment claim fails because Reed was a pretrial detainee at the time, and Eighth Amendment protections do not apply to pretrial detainees.
• The court grants Defendant McCurtain County District Judge Emily Maxwell's Motion to Dismiss because Plaintiff Reed failed to allege specific actions taken by Maxwell; his claims are based on speculation alone and do not state a claim on which relief may be granted under Rule 12(b)(6).
• The court grants Defendant McCurtain County Special Judge Mark Uptegrove's Motion to Dismiss. Claims are barred by Heck v. Humphrey because the suit attacks the validity of Reed's conviction. Additionally, claims are barred by the Rooker-Feldman doctrine as federal court lacks jurisdiction to review state court judgments. Judge Uptegrove is also entitled to absolute judicial immunity for acts made in the exercise of judicial discretion.

Remedies

• A separate judgment of dismissal shall be entered by the court.
• The court grants Defendant Matloff's Motion to Dismiss, dismissing Reed's claims against Defendant McCurtain County District Attorney Mark Matloff without prejudice.
• The court grants the Judicial Defendants' Motion to Dismiss, dismissing Plaintiff Reed's claims against Defendants McCurtain County District Judge Emily Maxwell and Special Judge Mark Uptegrove without prejudice.

Legal Principles

• The Rooker-Feldman doctrine prevents federal district courts from considering suits that amount to appeals of state-court judgments. Reed's claims against Uptegrove challenge the denial of his application for post-conviction relief, which the OCCA affirmed, making this a state court judgment that the federal court cannot review.
• Brady claims that seek evidence undermining a conviction necessarily imply the invalidity of the conviction and are barred by Heck. Brady claims have ranked within the traditional core of habeas corpus and outside the province of § 1983. Reed's Brady claim against Matloff is therefore barred.
• The Eighth Amendment's protections against cruel and unusual punishment do not apply to pretrial detainees. Reed was a pretrial detainee at the time of the incidents giving rise to his claims, so his Eighth Amendment claim fails.
• Dismissal under Rule 12(b)(6) is appropriate if the facts alleged fail to state a claim on which relief may be granted. A claim is plausible if facts raise a reasonable expectation that discovery will reveal evidence of the conduct necessary to establish the plaintiff's claim. The complaint must contain more than labels and conclusions.
• To establish a Napue violation, a defendant must show that the prosecution knowingly solicited false testimony or knowingly allowed it to go uncorrected when it appeared. If this showing is made, a new trial is warranted if the false testimony may have affected the outcome of the trial. Reed's Napue claim against Matloff is barred by Heck.
• In Oklahoma, the statute of limitations for a § 1983 claim is two years. A § 1983 claim accrues when the plaintiff has a complete and present cause of action. Reed's retaliation claim from 2006 is time-barred as Reed knew of the injury by February 2008 when he was convicted.
• Judicial defendants are entitled to absolute immunity from suit for civil damages for acts made in the exercise of judicial discretion. Defendant Uptegrove was performing judicial acts when he ruled on Reed's application for post-conviction relief, and thus is clothed with absolute judicial immunity.
• The Heck doctrine bars § 1983 claims that would necessarily imply the invalidity of a conviction or sentence. Reed's claims against Uptegrove and Matloff seeking damages, declaratory, or injunctive relief are barred because successful judgment would imply his conviction was invalid. The Cohen exception does not apply because Reed still has an available remedy to file a second or successive habeas petition.

Precedent Name

• Edwards v. Balisok
• Ashcroft v. Iqbal
• Rooker-Feldman doctrine
• Napue v. People of State of Illinois
• Cohen v. Longshore
• Heck v. Humphrey
• Skinner v. Switzer
• United States v. Harrell
• Andrews v. Heaton
• Colbruno v. Kessler
• Bell Atl. Corp. v. Twombly
• Wallace v. Kato

Cited Statute

• Oklahoma Statute of Limitations
• Habeas Corpus Authorization Statute
• Civil Rights Act

Judge Name

Passage Text

• Under the Rooker-Feldman doctrine, federal district courts have no jurisdiction to consider suits 'that amount to appeals of state-court judgments.' This doctrine applies to 'cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the [federal] district court proceedings commenced and inviting district court review and rejection of those judgments.' Reed clearly seeks review and rejection of Defendant Uptegrove's order denying his application for post-conviction relief.
• To the extent Reed's suit is meant to directly attack the validity of his conviction, his claims against Defendant Uptegrove must be dismissed 'as an improper use of Section 1983.' In Heck, the Supreme Court stated that, if judgment in favor of the prisoner plaintiff in a Section 1983 damages suit 'would necessarily imply the invalidity of his conviction or sentence[, then] the complaint must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated.'
• For the reasons discussed herein, the Judicial Defendants' Motion to Dismiss (Dkt. 18) and Defendant Matloff's Motion to Dismiss (Dkt. 20) are granted.