Harr v. Deberry
5:24-cv-00661
| E.D.N.C. | Jul 17, 2025Background
- Plaintiffs Sidney B. Harr, M.D. and Crystal Gail Mangum filed a civil rights suit challenging Mangum's conviction in North Carolina state court, alleging due process violations and misconduct by Durham District Attorney Santana Deberry.
- Mangum is currently incarcerated following her state conviction; Harr claimed standing as her advocate.
- Plaintiffs sought federal court orders to force the District Attorney to hold a hearing, permit witness testimony, and either prove Mangum’s guilt or vacate her conviction.
- Defendant Deberry moved to dismiss, arguing lack of subject matter jurisdiction (no standing) and failure to state a claim.
- Plaintiffs filed motions for subpoenas and summary judgment, which were stayed pending the motion to dismiss.
- The district court addressed only jurisdiction, finding plaintiffs lacked standing and the relief sought could not be granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing of Plaintiffs | Plaintiffs suffered due process violations; Harr can act in Mangum's interest | Plaintiffs have no injury or right; Harr cannot assert Mangum’s rights | Plaintiffs lack Article III standing |
| Redressability | Federal court can grant relief by ordering hearing and vacating conviction | Federal court lacks power to grant such relief | Relief not redressable by federal court |
| Federal Power Over State Convictions | Federal court can review Mangum’s conviction via civil rights suit | Relief barred by Rooker-Feldman and Heck doctrines | Court cannot review/vacate state convictions |
| Eleventh Amendment Immunity | Immunity inapplicable due to violations claimed | Immunity precludes relief against defendant | Relief barred by Eleventh Amendment |
Key Cases Cited
- McNutt v. Gen. Motors Acceptance Corp., 298 U.S. 178 (1936) (plaintiff bears burden of showing federal jurisdiction is appropriate)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard under Rule 12(b)(6) requires factual matter sufficient to state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must exceed speculative level to survive motion to dismiss)
- Warth v. Seldin, 422 U.S. 490 (1975) (plaintiff must assert their own legal rights)
- Linda R.S. v. Richard D., 410 U.S. 614 (1973) (no judicially cognizable interest in criminal prosecution of another)
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923) (federal courts cannot review state court decisions)
- D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (1983) (same as above, clarifying scope)
- Heck v. Humphrey, 512 U.S. 477 (1994) (civil rights actions cannot be used to collaterally attack underlying convictions)
- Wilkinson v. Dotson, 544 U.S. 74 (2005) (action barred if success would necessarily imply invalidity of conviction or sentence)
- Republic of Paraguay v. Allen, 134 F.3d 622 (4th Cir. 1998) (Eleventh Amendment bars federal relief voiding state conviction)