Engels v. Ryan, 7:13-cv-00751

Background

Plaintiff James Engels, proceeding pro se under 42 U.S.C. § 1983, challenges actions arising from a conditional discharge for alleged unlawful storage of tires and a subsequent revocation and re-sentencing.
Engels alleges he complied with the conditional discharge (fewer than 1,000 tires) but DEC Officer Jonathan Ryan submitted a false report saying the property was not cleaned.
As a result of the report and an affidavit by the ADA, Potsdam Town Court revoked the conditional discharge, subjected Engels to many court appearances, and imposed a potential fine in excess of $1 million; Engels later alleges County Court reversed the revocation on August 24, 2012.
Engels claims Ryan acted under color of state law, fabricated evidence, and was influenced by Town of Parishville Justice Frank Dunning.
Procedurally: Ryan moved to dismiss for failure to state a claim and on statute-of-limitations grounds; the Town of Potsdam moved to dismiss for failure to state a Monell claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ryan’s alleged fabrication and submission of false evidence to court states a § 1983 claim	Ryan knowingly submitted false information causing revocation of conditional discharge and liberty deprivations	Ryan argued failure to state a claim and that the claim was time-barred	Court denied dismissal: allegations plausibly plead a fabrication-of-evidence § 1983 claim and claim was timely because it accrued after the 2012 County Court reversal
Whether plaintiff's claim against Ryan is barred by the statute of limitations / Heck doctrine	Claim was premature until reversal; accrual occurred on August 24, 2012	Ryan argued claim was time-barred	Court held Heck barred suit until favorable termination; once reversed, suit (filed June 26, 2013) was timely
Whether Town of Potsdam is liable under Monell for Ryan’s conduct	Implied municipal liability based on local court actions and DEC involvement	Town argued no facts alleged showing a municipal policy/custom causing the constitutional violation	Court granted dismissal with prejudice as plaintiff failed to plausibly allege a policy, practice, or custom linking the Town to the constitutional violation
Whether pro se pleadings should be construed liberally to state claims	Pleadings and attachments (including post-filing reversal allegation) should be read to raise strongest arguments	Defendants relied on the complaint as insufficient	Court applied liberal pro se standard and considered plaintiff’s attachments and objections in assessing plausibility

Key Cases Cited

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim)
Ruotolo v. City of New York, 514 F.3d 184 (2d Cir. pleading standard discussion)
ATSI Communications, Inc. v. Shaar Fund, Ltd., 493 F.3d 87 (pleading must provide grounds to raise right to relief above speculative level)
Triestman v. Federal Bureau of Prisons, 470 F.3d 471 (pro se submissions construed to raise strongest arguments)
Fernandez v. Chertoff, 471 F.3d 45 (liberal construction of pro se civil rights complaints)
Monell v. Department of Social Services, 436 U.S. 658 (municipal liability requires policy, custom, or practice)
Heck v. Humphrey, 512 U.S. 477 (civil rights suit challenging conviction or sentence barred until favorable termination)
Zahrey v. Coffey, 221 F.3d 342 (fabrication-of-evidence can implicate due process)
Ricciuti v. New York City Transit Authority, 124 F.3d 123 (creating false information forwarded to prosecutors can violate fair-trial rights)