Lewis v. Reddick, 1:17-cv-00359

Plaintiff Na-Quan Kurt Lewis, a pretrial detainee, was arrested on weapons charges after a warrant issued July 11, 2016; Detective Ahmard Reddick interviewed him but Lewis invoked his Miranda rights and was returned to his cell.
Reddick was later criminally implicated in unrelated misconduct (arson and false statements) involving alleged attempts to frame a gang; Lewis alleges no direct connection between that misconduct and his charges.
Lewis alleges a “dirty” search warrant for his brother’s phone produced evidence leading to firearm charges; he claims late disclosure of discovery by prosecutor Albert Roop prevented a timely suppression motion.
Lewis sought dismissal of his state criminal case and money damages under 42 U.S.C. § 1983, naming Detective Reddick, Prosecutor Roop, Defense Counsel Natalie Woloshin, Judge Ferris Wharton, and Detective Devon Jones.
The District Court screened the complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A and dismissed the action: Jones was dismissed for lack of allegations; Judge Wharton dismissed based on judicial immunity; Roop dismissed based on absolute prosecutorial immunity; Woloshin dismissed for not acting under color of state law; Reddick dismissed for failure to state a plausible constitutional claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal involvement of Detective Devon Jones	Jones was a defendant in Lewis’s § 1983 claim	No facts allege Jones’s involvement	Dismissed for failure to plead personal involvement (frivolous)
Judicial actions by Judge Wharton	Judge’s refusal to accept self-representation and scheduling harmed Lewis	Judicial acts are protected by absolute immunity	Dismissed; Judge Wharton entitled to absolute judicial immunity
Prosecutorial conduct by Albert Roop (late discovery, plea deals)	Roop timed disclosures to prevent suppression motion and coerced plea bargaining	Prosecutorial acts in initiating/pursuing prosecution are immune	Dismissed; Roop protected by absolute prosecutorial immunity
Counsel Woloshin’s conduct	Woloshin refused to file motions and failed Lewis as appointed counsel	Public defenders are not state actors for § 1983 purposes when performing traditional functions	Dismissed; Woloshin not a state actor under § 1983
Detective Reddick’s conduct (interview, alleged link to gang/arson)	Reddick’s misconduct and alleged connection to gang activity tainted Lewis’s arrest/charges	No factual link shown between Reddick’s crimes and Lewis’s prosecution; interview ended once Lewis invoked rights	Dismissed for failure to state a plausible constitutional claim

Younger v. Harris, 401 U.S. 37 (1971) (federal courts generally abstain from interfering with pending state criminal proceedings)
Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity protects judges from monetary suits for judicial acts)
Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutors are absolutely immune for actions intimately associated with the judicial phase of the criminal process)
Polk County v. Dodson, 454 U.S. 312 (1981) (public defenders generally do not act under color of state law for § 1983 claims when performing traditional defense functions)
Neitzke v. Williams, 490 U.S. 319 (1989) (standards for dismissing frivolous claims under § 1915)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim to survive dismissal)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard and courts may disregard conclusory allegations)
West v. Atkins, 487 U.S. 42 (1988) (§ 1983 requires a person acting under color of state law)