JACKSON v. TYNER
1:20-cv-17426
D.N.J.May 4, 2021Background
- Plaintiff Mark Jackson, a pretrial detainee at Atlantic County Justice Facility, filed pro se §1983 and state-law claims after being charged with three felonies and later acquitted in September 2019.
- Jackson alleged Prosecutor Damon G. Tyner prosecuted him based on false and insufficient evidence and sought damages for approximately eleven months in jail, plus other losses; he also asserted defamation and emotional-distress claims.
- Jackson filed virtually identical complaints in two cases; the court treated one as a duplicate and dismissed it with prejudice.
- The court screened the remaining complaint under the prisoner/IFP screening rules and noted Jackson had not submitted a certified inmate trust fund statement as required by 28 U.S.C. §1915(a)(2).
- The District Court construed the federal claim as a Fourteenth Amendment malicious-prosecution claim under §1983 and analyzed whether Tyner is entitled to absolute prosecutorial immunity; the court dismissed the federal claim without prejudice and declined supplemental jurisdiction over state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prosecutorial immunity for malicious-prosecution claim under §1983 | Jackson alleges Tyner used false/insufficient evidence to prosecute him, causing detention and damages | Tyner is immune for acts intimately associated with initiating and presenting the prosecution | Court: Dismissed the §1983 malicious-prosecution claim without prejudice because Tyner is entitled to absolute immunity for bringing charges and presenting evidence at trial |
| Supplemental jurisdiction over state-law claims | State defamation and emotional-distress claims arise from same conduct and should be heard | Federal claim barred by immunity; court may decline supplemental jurisdiction | Court: Declined to exercise supplemental jurisdiction; state claims dismissed without prejudice |
| Duplicate filing | Jackson filed substantially identical complaints in two actions | N/A | Court: Dismissed Civil Action No. 20-17429 with prejudice as a duplicate of No. 20-17426 |
| IFP filing requirements / certified trust fund statement | Jackson did not provide the required certified inmate account statement | N/A | Court: Noted deficiency; if Jackson amends he must submit a certified trust fund statement and comply with §1915 procedures |
Key Cases Cited
- Imbler v. Pachtman, 424 U.S. 409 (1976) (establishes absolute prosecutorial immunity for actions intimately associated with the judicial phase of prosecution)
- Fogle v. Sokol, 957 F.3d 148 (3d Cir. 2020) (applies and explains prosecutorial immunity, distinguishing prosecutorial and investigatory functions)
- Kulwicki v. Dawson, 969 F.2d 1454 (3d Cir. 1992) (recognizes immunity for soliciting testimony in grand jury and probable-cause contexts)
- Burns v. Reed, 500 U.S. 478 (1991) (addresses immunity for prosecutors when appearing before judges to present evidence)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: plausibility requirement)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard establishing the plausibility framework)
- West v. Atkins, 487 U.S. 42 (1988) (elements required to state a §1983 claim)