Martin v. City of Memphis/Shelby County & Criminal Court, 2:17-cv-02432

Background

Plaintiff Rhakim Martin, a state prisoner, sued the City of Memphis/Shelby County, the Criminal Court, and 28 individual defendants under 42 U.S.C. § 1983 challenging events that led to his arrest, trial, conviction, and 16-year sentence. The complaint included allegations of false arrest/imprisonment, ineffective assistance of counsel, improper juror/sworn procedures, conspiracies, and supervisory liability.
Plaintiff sought release from confinement, removal of his 16-year sentence, and monetary damages.
Plaintiff proceeded in forma pauperis; the court screened the complaint under 28 U.S.C. § 1915(e)(2).
Plaintiff filed three motions to amend: two to add his attorney Eric Mogy as a defendant and one to add an exhibit (an indictment allegedly missing a signature).
The district court treated the complaint liberally (pro se) but concluded the allegations overlap with and necessarily call into question the validity of Martin’s conviction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Martin's § 1983 claims are cognizable while his conviction stands	Martin alleges constitutional and state-law violations (false arrest, false imprisonment, prosecutorial and judicial misconduct) and seeks release/expungement and money damages	Defendants argue the complaint attacks the conviction and is therefore barred by Heck	Court: Heck bars § 1983 claims that would necessarily imply invalidity of an unrevoked conviction; dismissal warranted
Whether Martin may recover money damages for conduct leading to conviction	Martin seeks monetary relief for wrongful arrest, prosecution, and procedures	Defendants assert money damages are barred because recovery would imply conviction invalidity (Edwards extension of Heck)	Court: Monetary damages barred because success would necessarily imply invalid conviction or sentence
Whether proposed amendments (adding attorney defendant; adding indictment exhibit) should be allowed	Martin seeks to add his attorney and an exhibit to challenge post‑conviction handling and alleged defective charging documents	Defendants argue amendments would be futile because they pursue the same relief that would invalidate the conviction	Court: Motions to amend denied as futile under Heck because claims would still imply invalidity of the conviction
Whether the in forma pauperis screening standard affects pleading treatment	Martin, as pro se, contends his filings should be liberally construed	Court must apply § 1915 screening while giving pro se complaints liberal construction, but plausibility and Heck limitations remain	Court: Even under liberal construction, plaintiff fails to state a cognizable § 1983 claim; dismissal stands

Key Cases Cited

Heck v. Humphrey, 512 U.S. 477 (1994) (a § 1983 claim that would necessarily imply the invalidity of a conviction is not cognizable until conviction is invalidated)
Edwards v. Balisok, 520 U.S. 641 (1997) (Heck extends to bar monetary damages claims that would imply invalidity of conviction or sentence)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions insufficient; pleadings must state a plausible claim)