Calderon v. Brown, 4:24-cv-04122

Agustin Calderon, a Texas inmate serving a life sentence for capital murder, filed a federal habeas corpus petition challenging his 2018 conviction.
Calderon's habeas case is pending before Judge Jeffrey Vincent Brown in the Southern District of Texas, with Bobby Lumpkin, TDCJ Director, as the respondent.
In this separate civil rights lawsuit under 42 U.S.C. § 1983, Calderon claims that Judge Brown and Lumpkin are violating his rights by not properly considering his habeas claims and circumstances (poverty, low education), refusing discovery and counsel, and permitting noncompliance with court orders.
Calderon sought declaratory and injunctive relief, including orders for the court and TDCJ to settle his habeas claims and permit gateway review of his actual innocence arguments.
As a prisoner proceeding in forma pauperis, Calderon's civil complaint was screened under the Prisoner Litigation Reform Act (PLRA), which mandates dismissal if the claims are not legally valid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
§ 1983 claim for rights violations in habeas proceedings	Calderon alleges rights violations by Judge Brown and Lumpkin during his habeas litigation	Defendants (implicitly per screening) acted within lawful discretionary/judicial roles; claims not cognizable	Not cognizable; dismissed under Heck v. Humphrey
Request for injunctive/declaratory relief related to pending habeas	Calderon seeks court orders to require particular action on his pending habeas claims	Defendants are immune; the relief would imply invalidity of criminal judgment	Not available under Heck unless conviction invalidated
Eligibility for monetary damages	Calderon claims damages for defendants’ actions relating to his pending federal case	Judge Brown is immune as a judicial officer; claim barred unless conviction set aside	Monetary claims dismissed with prejudice until Heck conditions met
Judicial immunity	Damages claim against Judge Brown for rulings on habeas case	Judge has absolute immunity for acts in judicial capacity	Judge Brown is immune; claims for damages dismissed

Heck v. Humphrey, 512 U.S. 477 (1994) (barring §1983 actions that would imply the invalidity of a criminal conviction unless the conviction is overturned)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (confirming that challenges to confinement must meet Heck's requirements)
Davis v. Tarrant County, Texas, 565 F.3d 214 (5th Cir. 2009) (judges are absolutely immune from damages claims for acts performed in judicial capacity)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints must do more than offer labels and conclusions—must state plausible claims)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se pleadings liberally construed but must allege more than conclusory statements)