Atwater v. Shaffer, 1:14-cv-01120

Plaintiff Lewis Atwater, a state inmate, filed a pro se § 1983 suit alleging Officer Shaffer (York County) made an illegal arrest and detention and seeks monetary damages and an "immediate pardon."
Plaintiff moved to proceed in forma pauperis; the court screened the complaint under the PLRA (28 U.S.C. §§ 1915A, 1915(e)).
The complaint contains minimal factual detail and does not identify the underlying criminal case in the pleading; court review of state dockets suggested Atwater was convicted in Commonwealth v. Atwater (York C.P. docket CP-67-CR-0002779-2009) and did not appeal.
The court found that a successful § 1983 claim for damages based on an unlawful arrest/detention would necessarily imply the invalidity of Atwater’s conviction or confinement.
Because Atwater had not shown his conviction has been reversed, expunged, or otherwise invalidated, the complaint is barred by Heck v. Humphrey and must be dismissed.
The dismissal was with prejudice for failure to state a claim; amendment was deemed futile. The court noted habeas corpus as the proper vehicle to challenge the validity/duration of confinement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Atwater may pursue § 1983 damages for alleged illegal arrest/detention that underlies a criminal conviction	Atwater alleges Shaffer effected an illegal arrest and detention and seeks damages and a pardon	Implicit defense: the suit would call into question the validity of Atwater's conviction (Heck bar)	Dismissed: Heck prevents § 1983 damages claim until conviction is invalidated
Whether the complaint survives PLRA screening for failure to state a claim	Atwater contends facts suffice to state unlawful arrest/detention claim	Complaint lacks sufficient factual detail and successful claim would imply invalid conviction	Dismissed under §1915(e)/§1915A as failing to state a claim
Whether the court should allow amendment	Atwater sought to proceed pro se; no detailed underlying criminal judgment provided	Court reviewed state docket and found no appeal or invalidation of conviction	Amendment would be futile; dismissal with prejudice
Proper remedy for challenging conviction or confinement	Atwater requested damages and a pardon via § 1983	Habeas corpus is the proper remedy to challenge fact/duration of confinement	Court declined to convert claim; advised habeas petition is the proper vehicle

Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 damages claim that would impugn validity of conviction barred until conviction is invalidated)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus is the exclusive remedy to challenge fact or duration of confinement)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (clarifies when habeas is the proper vehicle for challenges to confinement)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints must plead sufficient factual matter to state a claim)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must raise right to relief above speculative level)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints are liberally construed)
Alston v. Parker, 363 F.3d 229 (3d Cir. 2004) (futility of amendment standard in prisoner civil rights suits)
Grayson v. Mayview State Hospital, 293 F.3d 103 (3d Cir. 2002) (standards for dismissing prisoner civil rights complaints)
Roman v. Jeffes, 904 F.2d 192 (3d Cir. 1990) (conserving judicial resources in frivolous prisoner litigation)