Librace v. Valley
2:17-cv-00140
E.D. Ark.Nov 17, 2017Background
- Plaintiff David Librace, proceeding pro se, sued Andre Valley in his official capacity as city attorney under 42 U.S.C. § 1983 claiming Valley signed affidavits for arrest warrants without probable cause; one led to Librace’s arrest, prosecution, and conviction for communicating a false report.
- Librace sought injunctive relief to stop further alleged harassment, slander, and malicious prosecutions.
- Complaint pleads a broad pattern of deficient prosecutions (hearsay-based affidavits, nondisclosure of evidence/witnesses, biased trial practice) but identifies only one specific incident that resulted in his March 2017 conviction.
- Court limited its review to allegations in the complaint (plaintiff had attached additional documents in briefing that were not part of the complaint).
- Defendant moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing Rooker–Feldman, Heck bar, and failure to plead municipal-liability elements; court granted dismissal without prejudice and allowed 14 days to move to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court has jurisdiction over claims attacking arrest/prosecution/conviction | Librace contends arrest lacked probable cause and seeks injunction against further prosecution/harassment | Valley argues Rooker–Feldman bars federal review of state-court judgment | Held: Rooker–Feldman applies; claims amount to impermissible federal review of state conviction |
| Whether plaintiff's attack on arrest is barred by conviction | Arrest was unconstitutional for lack of probable cause, distinct from conviction | Valley: the conviction conclusively establishes probable cause; attack on arrest implies invalidity of conviction | Held: Conviction is conclusive on probable cause; attack would imply invalidity of conviction and is barred |
| Whether plaintiff's relief is barred by Heck v. Humphrey | Seeks injunctive relief, not damages, to prevent further prosecutions | Valley: Heck bars claims that would necessarily imply invalidity of conviction absent reversal/expungement/habeas | Held: Heck bars relief because success would necessarily imply invalidity and plaintiff has not shown reversal/expungement/habeas |
| Whether complaint plausibly pleads a broader pattern of improper affidavits/municipal liability | Librace alleges systemic practice of false affidavits and conspiracy involving city officials | Valley: complaint is conclusory and fails Twombly/Iqbal plausibility; official-capacity claims require municipal-liability pleading | Held: Complaint’s broader allegations are conclusory and fail Twombly/Iqbal; court did not reach municipal-liability issue due to other dismissals |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions not entitled to presumption of truth)
- Erickson v. Pardus, 551 U.S. 89 (pro se complaints construed liberally)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal district courts lack appellate jurisdiction over state-court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (Rooker–Feldman doctrine scope)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (clarifying Rooker–Feldman limits)
- Heck v. Humphrey, 512 U.S. 477 (§ 1983 claims implying conviction invalidity barred absent reversal/expungement/habeas)
- Wilkinson v. Dotson, 544 U.S. 74 (Heck applies regardless of form of relief sought)
- Robins v. Ritchie, 631 F.3d 919 (8th Cir. application of Rooker–Feldman)
- Brown v. Willey, 391 F.3d 968 (conviction is conclusive proof of probable cause)