GIBBS v. THE PHILA. POLICE DEPARMENT, 2:16-cv-05465

Amin Gibbs, proceeding pro se, sued multiple Philadelphia police officers and the Philadelphia Police Department under 42 U.S.C. § 1983 alleging false arrest/false imprisonment and malicious prosecution arising from a November 23, 2012 arrest, a December 2014 conviction (exonerated on homicide but convicted of lesser charges), and April 2015 sentencing.
Gibbs alleges evidence was manufactured, exculpatory evidence was withheld (Brady-type complaints), witnesses and cell‑phone evidence were not properly presented, and trial unfairness; he seeks reversal of conviction and $50 million.
Officer Craig Perry moved to dismiss for lack of personal involvement; other defendants moved to partially dismiss Gibbs’s claims.
The court applied Rule 12(b)(6) standards (liberally construing pro se pleadings) and considered Heck v. Humphrey and applicable statutes of limitations.
The court dismissed claims against Officer Perry for lack of pleaded personal involvement.
The court dismissed (1) all § 1983 claims and malicious prosecution claims that would imply invalidity of Gibbs’s 2014 convictions under Heck, and (2) false arrest/false imprisonment claims as time‑barred under Pennsylvania’s two‑year statute of limitations. The court found amendment futile and closed the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Officer Perry is liable under § 1983	Perry was one of the officers involved in misconduct leading to wrongful conviction	Perry lacked personal involvement; complaint does not allege his specific actions	Dismissed for failure to plead Perry’s personal involvement with particularity (no mention of Perry in complaint)
Whether § 1983 claims challenging convictions are cognizable now	Gibbs seeks damages and reversal based on Brady and manufactured evidence	Such claims impermissibly attack the validity of convictions and are barred by Heck until convictions are invalidated	Dismissed under Heck; plaintiff must first invalidate convictions before § 1983 damages claim proceeds
Whether malicious prosecution claim survives	Gibbs asserts prosecution was malicious due to fabrication and withheld exculpatory evidence	Defendants note criminal convictions remain, so no favorable termination	Dismissed: malicious prosecution requires prosecution termination in favor of accused, which Gibbs has not alleged
Whether false arrest/false imprisonment claims are timely	Gibbs claims arrest/continued detention are unconstitutional	Defendants argue Pennsylvania’s two‑year statute bars claims accrued in 2012/arraignment earlier than filing in 2016	Dismissed as time‑barred under Pa. Statute of Limitations; false arrest accrued Nov 23, 2012; false imprisonment accrued at arraignment

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for Rule 12(b)(6) pleadings)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading framework)
Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir. 1988) (personal involvement requirement for § 1983 liability)
Heck v. Humphrey, 512 U.S. 477 (1994) (bar on § 1983 claims that would invalidate standing convictions)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s duty to disclose exculpatory evidence)
Skinner v. Switzer, 562 U.S. 521 (2011) (distinguishing habeas and § 1983 in certain contexts)
Mala v. Crown Bay Marina, Inc., 704 F.3d 239 (3d Cir. 2013) (pro se plaintiffs must plead sufficient facts)
Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (leave to amend required unless futile)
Wallace v. Kato, 549 U.S. 384 (2007) (accrual rules for false imprisonment claims)