Johnson v. Lorain County
1:19-cv-02674
| N.D. Ohio | Mar 11, 2020Background:
- Jarrod S. Johnson, proceeding pro se, is detained in the Lorain County Jail awaiting trial on murder, attempted murder, aggravated robbery, and felonious assault charges.
- Johnson filed a 42 U.S.C. § 1983 complaint against the "Lorain County State of Ohio" seeking dismissal of the criminal charges, damages, and other relief, alleging his speedy-trial rights were violated.
- The Court reviewed the complaint under 28 U.S.C. § 1915A, which requires prompt screening of prisoner suits and dismissal of frivolous or legally deficient claims.
- The Court found Johnson’s claim attacks the fact/duration of his confinement and thus falls within habeas jurisdiction under Preiser v. Rodriguez rather than § 1983.
- The Court noted Betterman v. Montana and related precedent that the sole remedy for a speedy-trial violation is dismissal of the charges, and that § 1983 is not an alternative to habeas relief.
- The complaint was dismissed under § 1915A, and the Court certified that any appeal could not be taken in good faith.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a pretrial detainee may use § 1983 to obtain dismissal/release for alleged speedy-trial violations | Johnson contends his pretrial incarceration violated his speedy-trial rights and seeks dismissal/damages via § 1983 | The State contends challenges to the fact or duration of confinement require habeas relief; § 1983 is inappropriate | Court held Preiser bars use of § 1983 for claims attacking fact/duration of confinement; dismissal required |
| Proper remedy and procedural route for a speedy-trial claim by a pretrial detainee | Johnson seeks dismissal of charges and monetary relief in this § 1983 action | State asserts the sole remedy for a speedy-trial violation is dismissal of charges and that state remedies/habeas must be exhausted | Court held the sole remedy is dismissal of charges; plaintiff must pursue habeas after exhausting state remedies; § 1983 claim fails and is dismissed |
Key Cases Cited
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (when a prisoner challenges the fact or duration of confinement, the exclusive federal remedy is habeas corpus)
- Betterman v. Montana, 136 S. Ct. 1609 (2016) (the sole remedy for a speedy-trial violation is dismissal of the charges)
- Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (district courts must screen prisoner complaints under 28 U.S.C. § 1915A)
- Brown v. Romanowski, 845 F.3d 703 (6th Cir. 2017) (discussing remedies and limitations for pretrial detainee claims under federal law)