United States District Court, E.D. Louisiana
ORDER AND REASONS
SARAH S. VANCE, District Judge.
Before the Court is defendants Deputy John Doe's and Sheriff Rodney J. Strain's motion for summary judgment. The Court grants defendants' motion as to plaintiff's federal claims because these claims are barred by the Heck doctrine. The Court declines to exercise supplemental jurisdiction over plaintiff's pendent state law claims and dismisses these claims without prejudice.
Plaintiff alleges that on July 29, 2012, he was lawfully executing a Right of Repossession for his employer, Quality Auto Brokerage, when he was pulled over in the repossessed vehicle by a St. Tammany Parish Deputy. Plaintiff claims that he showed the repossession paperwork to the deputy but was arrested nonetheless. Plaintiff was charged with felony theft of an automobile and held in St. Tammany Parish Jail. At the time of his arrest, plaintiff was on probation stemming from a felony conviction in Orleans Parish. As a result, the Louisiana Department of Corrections issued a "probation hold" that authorized defendants to detain plaintiff without bail "as a probation violator for New Orleans." After six weeks of detention, plaintiff pleaded guilty to simple criminal trespass under La. Rev. Stat. § 14:63, and was sentenced to time served. Although plaintiff's sentence was imposed on September 11, 2012, defendants did not release plaintiff at that time because the Louisiana Department of Corrections' probation hold was still in place. The Department of Corrections lifted the probation hold on September 26, 2012, and defendants released plaintiff the same day.
On July 29, 2013, plaintiff filed this suit against St. Tammany Parish, St. Tammany Parish Sheriff Rodney Strain, and an unknown deputy. He seeks damages for false imprisonment under Louisiana Law, claiming that because he was attempting to effect a lawful repossession, his arrest was without probable cause. He further alleges that the felony charges were baseless and made it impossible for him to secure his release pending trial.
Plaintiff also seeks damages pursuant to 42 U.S.C. § 1983 for the alleged violation of his rights under the Fourth, Fifth, Eighth, and Fourteenth Amendments to the U.S. Constitution. He alleges that the defendants violated these rights by (1) arresting him without probable cause, (2) detaining him for a period of six weeks, (3) detaining him for an additional two weeks after he was ordered to be released, and (4) failing to provide supervision and proper training to prevent these incidents.
Summary judgment is warranted when "the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a); see also Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986); Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994). When assessing whether a dispute as to any material fact exists, the Court considers "all of the evidence in the record but refrain[s] from making credibility determinations or weighing the evidence." Delta & Pine Land Co. v. Nationwide Agribusiness Ins. Co., 530 F.3d 395, 398-99 (5th Cir. 2008). All reasonable inferences are drawn in favor of the nonmoving party, but "unsupported allegations or affidavits setting forth ultimate or conclusory facts and conclusions of law are insufficient to either support or defeat a motion for summary judgment." Galindo v. Precision Am. Corp., 754 F.2d 1212, 1216 (5th Cir. 1985)(internal quotations omitted); see also Little, 37 F.3d at 1075.
If the dispositive issue is one on which the moving party will bear the burden of proof at trial, the moving party "must come forward with evidence which would entitle it to a directed verdict if the evidence went uncontroverted at trial." Int'l Shortstop, Inc. v. Rally's, Inc., 939 F.2d 1257, 1264-65 (5th Cir. 1991)(internal quotations omitted). The nonmoving party can then defeat the motion by either countering with evidence sufficient to demonstrate the existence of a genuine dispute of material fact, or "showing that the moving party's evidence is so sheer that it may not persuade the reasonable fact-finder to return a verdict in favor of the moving party." Id. at 1265.
If the dispositive issue is one on which the nonmoving party will bear the burden of proof at trial, the moving party may satisfy its burden by merely pointing out that the evidence in the record is insufficient with respect to an essential element of the nonmoving party's claim. See Celotex, 477 U.S. at 325. The burden then shifts to the nonmoving party, who must, by submitting or referring to evidence, set out specific facts showing that a genuine issue exists. See id. at 324. The nonmovant may not rest upon the pleadings, but must identify specific facts that establish a genuine issue for trial. See, e.g., id.; Little, 37 F.3d at 1075 ("Rule 56 mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party's case, and on which that party will bear the burden of proof at trial.'" (quoting Celotex, 477 U.S. at 322)).
Defendants move for summary judgment arguing that plaintiff's claims under 42 U.S.C. § 1983 should be dismissed under the doctrine announced in Heck v. Humphrey, 512 U.S. 477 (1994). Defendants argue that plaintiff's guilty plea to criminal trespass precludes his Section 1983 claim for unlawful arrest and detention because this conviction has not been overturned or otherwise called into question. Plaintiff counters arguing that Heck is inapplicable because plaintiff pleaded to a different offense, criminal trespass, than the original charge brought against him, theft of a motor vehicle.
In Heck, a prisoner who had been convicted of voluntary manslaughter brought an action under Section 1983 against police and prosecutors, arguing that his arrest and conviction were unlawful. The suit sought only damages. It did not request injunctive relief or release from custody. Heck, 512 U.S. at 478-79. The Court noted that Section 1983 created a species of tort liability analogous to the common-law tort action of malicious prosecution. It noted that an action for malicious prosecution requires that the criminal proceedings be terminated in favor of the accused. Otherwise, a convicted defendant could mount a collateral attack on his conviction in the guise of a civil suit. Id. at 483-485.
Accordingly, the Court held that Section 1983 claims for damages are "not appropriate vehicles for challenging the validity of outstanding criminal judgments...." Id. at 486. A plaintiff may bring a Section 1983 action that would necessarily imply the unlawfulness of his ...