Ashford v. Heisey
1:25-cv-00660
M.D. Penn.Jun 12, 2025Background
- Alfred Ashford, Jr., a state prisoner, filed a pro se complaint and application to proceed in forma pauperis against probation officer Michael Heisey and Dauphin County Adult Probation (DCAP).
- Ashford suffers from cognitive impairments due to a past brain aneurysm and alleges that his disability was known to Heisey.
- Ashford claims Heisey failed to adequately explain Megan’s Law registration requirements, especially regarding the use of automobiles, and coerced Ashford to sign related documents under duress.
- Ashford seeks dismissal of his criminal conviction for failure to register, his release from incarceration, emotional distress damages, and reimbursement of incarceration costs.
- The court granted Ashford’s application to proceed in forma pauperis but screened his complaint under §1915A and §1915(e)(2) for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Dismissal of criminal conviction and release | Ashford seeks dismissal of failure to register conviction and release from custody due to alleged ADA violations | Relief of this type unavailable in civil action; appropriate vehicle is habeas corpus | Dismissed without prejudice to seek habeas relief |
| ADA Title II claim for emotional distress damages | Ashford alleges discrimination and seeks emotional distress damages under ADA Title II | Damages for emotional distress are not recoverable and claim is also Heck-barred | Dismissed with prejudice |
| Challenge to conviction under ADA claim | Ashford argues his disability prevented knowing failure to register, impacting the validity of his conviction | Allowing claim would imply invalidity of standing criminal judgment (Heck bar) | Dismissed; may refile if conviction is invalidated |
| Leave to amend complaint | Ashford may want to amend to cure defects | Amendment would be futile as claims are legally barred | Leave to amend denied |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (pro se litigation standards and IFP determinations)
- Preiser v. Rodriguez, 411 U.S. 475 (civil challenges to imprisonment must be via habeas corpus)
- Heck v. Humphrey, 512 U.S. 477 (bar on civil claims that would undermine uninvalidated criminal conviction)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading requirements and plausibility)