Darren Talbert v. Commonwealth of Pennsylvania, 667 F. App'x 778

Darren Talbert, a state prisoner, filed a pro se § 1983/racketeering and state tort complaint arising from his 2012 arrest, prosecution, and conviction in Delaware County, PA.
He sued about 20 defendants, including prosecutors, defense attorneys, police, a judge, Delaware County, and the Commonwealth, alleging false arrest, malicious prosecution, falsified evidence, unlawful conviction/imprisonment, and intentional infliction of emotional distress.
The District Court screened and dismissed the complaint with prejudice under 28 U.S.C. § 1915, finding many claims barred because Talbert’s convictions had not been invalidated, many claims failed to state a claim, and others were time-barred; state claims were dismissed without exercising supplemental jurisdiction.
Talbert moved for reconsideration, citing pro se status, incarceration, and lack of legal knowledge; the District Court denied the motion, concluding amendment could not cure the defects.
Talbert appealed the dismissal and the denial of reconsideration; the Third Circuit exercised de novo review of the § 1915 dismissal and plenary review to the extent legal questions were involved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Talbert can pursue claims that would imply invalidity of his conviction	Talbert alleged fabricated evidence and conspiracies causing his conviction and seeks damages	Defendants argued such claims are barred until conviction is invalidated	Dismissed under Heck: Talbert must first invalidate conviction before § 1983 damages claim proceeds
Whether Talbert’s remaining federal claims are timely	Talbert argued merits despite procedural defects and delay	Defendants argued claims are time-barred under Pennsylvania statutes of limitations	Dismissed as time-barred for non-Heck-implicated claims
Whether the District Court should retain supplemental jurisdiction over state-law claims	Talbert sought to keep state claims in federal court	Defendants argued federal claims were dismissed, so supplemental jurisdiction should be declined	District Court properly declined to exercise supplemental jurisdiction under 28 U.S.C. § 1367(c)(3)
Whether reconsideration should be granted given pro se status and incarceration	Talbert argued procedural disadvantages warranted relief or leave to amend	Defendants argued no basis for reconsideration; defects incurable by amendment	Denial of reconsideration affirmed; no intervening law, new evidence, or clear error shown; amendment would not cure defects

Heck v. Humphrey, 512 U.S. 477 (a § 1983 claim that would imply the invalidity of conviction is barred unless the conviction has been invalidated)
Allah v. Seiverling, 229 F.3d 220 (3d Cir. 2000) (de novo review applicable to § 1915 screening dismissals)
Max’s Seafood Café v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (standards for granting reconsideration)
Koshatka v. Philadelphia Newspapers, Inc., 762 F.2d 329 (3d Cir. 1985) (review standard for denial of reconsideration involving legal questions)
Houston v. Lack, 487 U.S. 266 (prisoner mailbox rule for filing dates)