GUTHRIE v. CLINE
4:25-cv-00062
| S.D. Ind. | Jun 30, 2025Background
- Tyler Guthrie, proceeding pro se, brought a federal action against various officials and entities related to his arrest and prosecution in Lawrence County, Indiana.
- Guthrie alleged that Officer Sarah Haluda unlawfully stopped and detained him, used excessive force, and falsely executed a probable cause affidavit leading to charges and legal consequences.
- Guthrie’s subsequent state court proceedings included contempt orders, prosecution for driving offenses, revocation of pretrial release, and conditions following a guilty plea.
- Guthrie sought leave to proceed in forma pauperis and filed for emergent injunctive relief against state officials and entities, aiming to halt ongoing state proceedings and penalties.
- The district court screened the Second Amended Complaint, evaluated motions to proceed in forma pauperis, and considered Guthrie’s request for a temporary restraining order (TRO).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| In forma pauperis status | Guthrie sought to waive prepayment of fees due to indigency. | Not opposed/opinion cited statutory limits. | Granted; filing fee excused up front but remains owed. |
| Viability of Section 1983 claim against Officer Haluda | Haluda unlawfully stopped, detained, and used force against Guthrie. | Not yet responded; addressed at screening stage. | Claim may proceed against Officer Haluda. |
| Claims against judges, prosecutor, state entities | Actions by judges, prosecutor, and state officials were unlawful and violated rights. | Immunity doctrines and lack of jurisdiction bar the claims. | Dismissed: barred by judicial/prosecutorial/sovereign immunity and Rooker-Feldman doctrine. |
| Request for TRO/injunctive relief against state court proceedings | Sought to enjoin ongoing state actions and penalties. | Relief not proper; court lacks jurisdiction; Anti-Injunction Act applies. | Denied: no likelihood of success and relief barred by federal principles. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading must show plausible entitlement to relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (detailed factual allegations not required, but threadbare recitals are not enough)
- Mireles v. Waco, 502 U.S. 9 (judicial immunity from suit for judicial actions)
- Fitzpatrick v. Bitzer, 427 U.S. 445 (states generally immune from suit under Eleventh Amendment)
- Lewis v. Clarke, 581 U.S. 155 (sovereign immunity applies to state officers in official capacity)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (federal lower courts cannot review state court judgments)