Andy Buxton v. Iva Dougherty
686 F. App'x 125
| 3rd Cir. | 2017Background
- Buxton appeals a district court dismissal for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B) and § 1915A(b)(1).
- Buxton sought damages and injunctive relief in a civil rights suit alleging fabrication of evidence, perjured testimony, and violation of grand jury secrecy related to pending criminal charges.
- Criminal charges against Buxton in Pennsylvania included drug-related and corrupt-organization offenses; judgments and dispositions occurred after the civil action was filed.
- The district court held Heck v. Humphrey bars the § 1983 claims and abstained under Younger v. Harris regarding the requested injunctions.
- The court suggested amendment would be futile, but the Third Circuit reversed to allow amendment to possibly avoid Heck.
- The panel remanded for Buxton to amend, noting that if Heck would bar claims post-amendment, dismissal should be without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Heck bar damages claims here? | Buxton argues some claims may not retroactively attack valid judgments. | Defendants contend Heck bars any damages claims arising from the conviction. | Remand to allow amendment; Heck may not bar all claims. |
| Can Buxton meet favorable termination for any charges? | Some charges may have favorable termination despite others, enabling § 1983 damages. | A mixed outcome does not automatically yield favorable termination for the proceeding as a whole. | Possibility exists; proceed to amendment to show favorable termination for some claims. |
| Should the district court have allowed amendment instead of dismissal? | Amendment could cure pleading defects and avoid dismissal on Heck grounds. | amendment would be futile given Heck and other doctrines. | Yes, the district court should permit amendment. |
| Was Younger abstention proper for the injunctive relief aspect? | Emergency or extraordinary circumstances could justify enjoining state proceedings. | There were pending state criminal proceedings and no exceptional factors; abstention proper. | Abstention proper; ruling preserved. |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (bar on § 1983 damages requiring invalidated conviction)
- Wallace v. Kato, 549 U.S. 384 (2007) (unrelated convictions important for accrual and Heck scope)
- Dique v. New Jersey State Police, 603 F.3d 181 (3d Cir. 2010) (clarified Heck applicability when conviction exists at accrual)
- Kossler v. Crisanti, 564 F.3d 181 (3d Cir. 2009) (favorable termination where some charges resolved differently)
- Smith v. Holtz, 87 F.3d 108 (3d Cir. 1996) (pleading standards and futility considerations in dismissal)
- Curry v. Yachera, 835 F.3d 373 (3d Cir. 2016) (remedies after Heck proceedings and post-conviction context)
- Sprint Commc'ns v. Jacobs, 134 S. Ct. 584 (2013) (parallel state proceedings require abstention from enjoining)
- Hilfirty v. Shipman, 91 F.3d 573 (3d Cir. 1996) (favorable termination and sufficiency of termination for claims)