Charles Floyd, Jr. v. Attorney General Pennsylvania, 17-2823

Floyd, a probationer, filed a § 1983 amended complaint challenging searches, arrests, and related conduct arising from two Dauphin County incidents (Feb 11 and Apr 11, 2014) that led to drug convictions.
He alleged warrantless searches of his residence/bedroom, consent limited to living quarters, falsified reports (dates/times/docket numbers), failure to file a probable-cause affidavit, ignored suppression motion, and malicious prosecution/fabrication of evidence.
Defendants named included the Commonwealth of Pennsylvania, the Attorney General, a state judge, detectives, and probation officers; Floyd sought damages and suppression/return of evidence.
The District Court adopted a magistrate judge’s report concluding the amended complaint failed to state a claim and dismissed it with prejudice; the court also denied Floyd’s request for appointed counsel.
On appeal the Third Circuit reviewed de novo, considered § 1915 screening, and affirmed summary dismissal and denial of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal involvement / state-defendant liability	Floyd named AG and judge as defendants for actions surrounding his prosecution and evidence	AG and judge lacked personal involvement; Commonwealth immune from suit	Dismissal affirmed: no personal involvement; Eleventh Amendment bars suit against state
Malicious prosecution / fabrication of evidence	Officers falsified reports and deposition; claims seek damages for misconduct	Conviction not invalidated; Heck bars § 1983 claims that would imply invalidity of conviction	Dismissal affirmed under Heck because criminal proceedings not terminated in Floyd’s favor
Fourth Amendment: searches and seizures (warrantless searches, arrests, seizures of evidence)	Searches exceeded consent; arrests were without warrant and lacked probable cause	Floyd was on probation; officers could search with reasonable suspicion and seize probation-violative contraband; probable cause existed due to contraband	Dismissal affirmed: searches and seizures lawful under probation search standards; no allegation negating reasonable suspicion or probable cause
Appointment of counsel	Floyd requested appointed counsel for prosecution of his claims	Court found no abuse of discretion in denying appointment under Tabron factors	Denial of appointed counsel affirmed; court also denied appointment on appeal

Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir. 1988) (personal involvement required for supervisory liability)
Idaho v. Coeur d’Alene Tribe of Idaho, 521 U.S. 261 (U.S. 1997) (Eleventh Amendment principles on suits against states)
Lavia v. Pa. Dep’t of Corr., 224 F.3d 190 (3d Cir. 2000) (limitations on suits against state entities/officials)
Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (§ 1983 claims that imply invalidity of conviction barred until conviction is invalidated)
United States v. Knights, 534 U.S. 112 (U.S. 2001) (probationer search standard: reasonable suspicion can justify search)
James v. City of Wilkes-Barre, 700 F.3d 675 (3d Cir. 2012) (elements for false arrest and probable cause analysis)
Tabron v. Grace, 6 F.3d 147 (3d Cir. 1993) (standards for appointment of counsel in civil cases)
Alvin v. Suzuki, 227 F.3d 107 (3d Cir. 2000) (futility of amendment standard)
Bradford v. Scherschligt, 803 F.3d 382 (9th Cir. 2015) (fabrication-of-evidence claims treated like malicious prosecution for accrual under Heck)