Craig Armstrong v. Villa Park Police Department
874 F.3d 1004
| 7th Cir. | 2017Background
- Armstrong was convicted (2011) for failing to register as a sex offender; the Illinois Appellate Court later reversed, finding his prior plea did not require registration, and the State dismissed charges.
- Armstrong filed a § 1983 suit alleging police hid exculpatory evidence, fabricated documents, and prosecuted him despite knowing he was not required to register.
- The district court screened and dismissed Armstrong’s complaint and amended complaint under 28 U.S.C. § 1915(e)(2)(B), denied appointment of counsel, and entered judgment.
- Armstrong filed a post-judgment motion invoking Rules 59(e) and 60(b), reiterating his need for court-appointed counsel; the district court denied relief as untimely under Rule 59(e) and found no Rule 60(b)(1–3) grounds.
- On appeal the Seventh Circuit held the district court abused its discretion by failing to apply the Pruitt two-step inquiry before denying counsel and that the denial could constitute extraordinary circumstances warranting Rule 60(b) relief.
- The Seventh Circuit vacated the denial of post-judgment relief and remanded, directing the district court to reconsider counsel appointment under Pruitt and to consider consolidation/assignment issues if the case survives pleading.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Rule 59(e) motion | Armstrong treated his post-judgment filing as raising Rule 59(e) grounds to alter judgment | District court: motion filed >28 days after judgment, so untimely | Court affirmed that Rule 59(e) was untimely as to the underlying dismissal, but appeal limited to denial of post-judgment relief |
| Rule 60(b) relief | Armstrong argued district court mishandled requests for counsel and that constituted grounds for relief | District court: no mistake, new evidence, or fraud under Rule 60(b)(1–3); denied relief | Seventh Circuit found denial of counsel could be extraordinary circumstances under Rule 60(b)(6) and remanded for further consideration |
| Denial of court-appointed counsel (Pruitt standard) | Armstrong said he tried to obtain counsel and is not competent to litigate complex claims | District court denied because plaintiff had one chance to amend and failed to state a claim, without applying Pruitt | Court held district court abused its discretion by failing to perform the Pruitt two-step inquiry and remanded for that analysis; recommended strong consideration of appointing counsel |
| Sufficiency of pleaded claims (Brady / malicious prosecution) | Armstrong alleged concealment of a fax denying registration and fabrication/lying to secure indictment | Defendants and district court treated claims as inadequately pleaded or barred by Heck/collateral-challenge rule | Seventh Circuit noted the amended complaint plausibly alleged Brady-style suppression and facts consistent with malicious prosecution; counsel might better articulate claims, so dismissal/conclusion premature without proper counsel inquiry |
Key Cases Cited
- Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (en banc) (two-step test for appointing counsel to indigent civil litigant)
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (favorable-termination rule limiting § 1983 damages claims that would imply invalidity of conviction)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution’s duty to disclose exculpatory evidence)
- Steidl v. Fermon, 494 F.3d 623 (7th Cir. 2007) (Brady claim standards in § 1983 context)
- Childress v. Walker, 787 F.3d 433 (7th Cir. 2015) (district court must adequately address request for counsel)
- Henderson v. Ghosh, 755 F.3d 559 (7th Cir. 2014) (standard of review for denial of appointed counsel)
- Trade Well Int’l v. United Cent. Bank, 825 F.3d 854 (7th Cir. 2016) (abuse-of-discretion standard for Rule 60(b) review)
- Colbert v. City of Chicago, 851 F.3d 649 (7th Cir. 2017) (malicious prosecution elements under Illinois law in § 1983 context)
- Davis v. Moroney, 857 F.3d 748 (7th Cir. 2017) (district court’s mishandling of counsel requests can justify Rule 60(b)(6) relief)
- Donald v. Cook Cty. Sheriff’s Dep’t, 95 F.3d 548 (7th Cir. 1996) (court delay in ruling on counsel motions may contribute to extraordinary circumstances)
- Whitaker v. Milwaukee Cty., 772 F.3d 802 (7th Cir. 2014) (pleaded factual allegations control over imperfect legal labels)
- Avila v. CitiMortgage, Inc., 801 F.3d 777 (7th Cir. 2015) (pleading standards and the importance of factual allegations)
- Johnson v. City of Shelby, 135 S. Ct. 346 (U.S. 2014) (lawyer’s mislabeling of cause of action does not justify dismissal when facts are alleged)
- People v. Armstrong, 50 N.E.3d 745 (Ill. App. Ct. 2016) (state appellate decision reversing Armstrong’s conviction for failing to register)