Frederick Manuel v. Rosemary Lehmberg
690 F. App'x 245
| 5th Cir. | 2017Background
- Plaintiff Frederick Delloyd Manuel, a Texas inmate serving life without parole for capital murder, sued under 42 U.S.C. § 1983 alleging a pretextual traffic stop, false arrest/false imprisonment, malicious prosecution, and an excessive bond tied to a separate robbery charge.
- Manuel alleged APD officers Staniszwski, Ehlert, and Nelson orchestrated the stop and that prosecutors Lehmberg and Young later falsely arrested/charged him pursuant to a warrant.
- Manuel contends the high $750,000 bond was designed to keep him imprisoned until unrelated capital-murder proceedings concluded; robbery charges were later dismissed after his murder conviction.
- The district court dismissed Manuel’s complaint as frivolous and for failure to state a claim; Manuel appealed.
- The Fifth Circuit affirmed, holding prosecutors’ claims barred by Eleventh Amendment or prosecutorial immunity, many claims time-barred, some barred by Heck, and that the plaintiff had adequate opportunity to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are official-capacity claims against prosecutors barred by the Eleventh Amendment? | Manuel sued Lehmberg and Young in official capacity for damages. | Defendants invoked Eleventh Amendment immunity for state actors sued in official capacity. | Held: Barred by Eleventh Amendment. |
| Are individual-capacity claims against prosecutors barred by absolute prosecutorial immunity? | Manuel alleged prosecutorial acts (setting bond, failing to respond to motions, examining trial issues) gave rise to § 1983 liability. | Prosecutors argued actions were prosecutorial and thus absolutely immune. | Held: Prosecutorial immunity applies; claims barred. |
| Are claims for unconstitutional stop, false arrest/imprisonment, and malicious prosecution time-barred? | Manuel argued claims timely or began accruing later (e.g., on release). | Defendants argued Texas two-year limitations applies and accrual began when plaintiff knew of injury or when detained by legal process. | Held: Unconstitutional stop and false arrest/imprisonment claims time-barred; malicious prosecution fails as a matter of law. |
| Does a claim that challenges pretrial publicity and affects the murder trial implicate Heck? | Manuel claimed Ehlert’s public statements violated his Sixth Amendment fair-trial rights. | Defendants argued successful § 1983 claim would imply invalidity of the murder conviction. | Held: Claim barred by Heck because conviction remains uninvalidated. |
| Did the district court abuse discretion by not allowing amendment or holding an evidentiary hearing? | Manuel argued he was denied opportunity to amend and to develop the record. | District court provided a questionnaire for a more definite statement and found plaintiff had pled his best case. | Held: No abuse; plaintiff had opportunity to amend and failed to state a viable claim. |
Key Cases Cited
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (official-capacity suits treated as suits against the state; Eleventh Amendment implications)
- Rykers v. Alford, 832 F.2d 895 (absolute prosecutorial immunity principles)
- Owens v. Okure, 488 U.S. 235 (§ 1983 borrows state personal-injury statute of limitations)
- Pete v. Metcalfe, 8 F.3d 214 (Texas two-year limitations period applies to § 1983 actions)
- Wallace v. Kato, 549 U.S. 384 (accrual for false imprisonment/false arrest claims runs from detention pursuant to legal process)
- Castellano v. Fragozo, 352 F.3d 939 (malicious prosecution standards under § 1983)
- Heck v. Humphrey, 412 U.S. 477 (bar on § 1983 claims that would imply invalidity of a conviction)
- Adepegba v. Hammons, 103 F.3d 383 (dismissal as frivolous counts as a strike under 28 U.S.C. § 1915(g))