Gabriel Pittman v. William Clinton
673 F. App'x 139
| 3rd Cir. | 2017Background
- Plaintiff Gabriel Pittman, a Pennsylvania state prisoner, pleaded guilty in 1998 to third-degree murder and related offenses and was sentenced to 26–59 years; state and federal post-conviction efforts were unsuccessful.
- Pittman filed a federal § 1331 complaint challenging AEDPA provisions: 28 U.S.C. § 2244(d)’s one-year time limit and § 2244(b)’s limits on second or successive habeas petitions, and sought money damages related to his conviction.
- The District Court dismissed the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i), finding the constitutional challenges meritless and damages unavailable, and denied a Fed. R. Civ. P. 59(e) motion for reconsideration.
- Pittman also argued § 1915(e) screening procedures violated the Fourth Amendment and Article III; he sought permission to file a late response to a notice of possible summary action.
- The Third Circuit exercised plenary review of the dismissal and abuse-of-discretion review of the Rule 59(e) denial, and summarily affirmed the District Court’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of AEDPA’s one-year statute of limitations (§ 2244(d)) | AEDPA’s one-year limit is unconstitutional | AEDPA time limit is constitutional and has been upheld | Court held challenge meritless; AEDPA’s time limit constitutional |
| Constitutionality of AEDPA’s restrictions on second/successive petitions (§ 2244(b)) | Restrictions violate constitutional rights | Restrictions are constitutional constraints on habeas practice | Court held challenge meritless; restrictions constitutional |
| Claim for money damages based on unlawful conviction | Pittman sought damages tied to his conviction | Damages barred because success would imply invalidity of conviction unless conviction invalidated | Court held damages unavailable absent prior invalidation of conviction (Heck/Edwards rule) |
| Constitutionality of § 1915(e) screening procedures | § 1915(e) violates the Fourth Amendment and Article III | § 1915(e) screening is lawful and widely upheld | Court rejected Pittman’s challenge; screening provisions valid |
Key Cases Cited
- Tinker v. Moore, 255 F.3d 1331 (11th Cir. 2001) (upholding AEDPA’s timeliness provision)
- Green v. White, 223 F.3d 1001 (9th Cir. 2000) (same)
- Miller v. Marr, 141 F.3d 976 (10th Cir. 1998) (same)
- Felker v. Turpin, 518 U.S. 651 (1996) (upholding restrictions on second or successive habeas petitions)
- Edwards v. Balisok, 520 U.S. 641 (1997) (damages claim barred if success would imply invalidity of conviction or sentence)
- Heck v. Humphrey, 512 U.S. 477 (1994) (favorable termination rule for prisoner civil rights damages claims)
- Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (discussion and application of § 1915(e) screening)
- Lazaridis v. Wehmer, 591 F.3d 666 (3d Cir. 2010) (standards for Rule 59(e) relief)