947 F.3d 1191
9th Cir.2020Background
- Four men (Roberts, Frese, Pease, Vent) were convicted of a 1997 murder and imprisoned for decades.
- Post-conviction proceedings produced a new confession and corroborating evidence; after extensive discovery and an evidentiary hearing, prosecutors offered a settlement.
- Under a Settlement Agreement and judicially entered stipulation, the Alaska Superior Court vacated the convictions, dismissed indictments, and released three plaintiffs; the agreement included a global release and a stipulation that the original verdicts had been validly entered.
- Plaintiffs later sued the City of Fairbanks and officers under 42 U.S.C. § 1983 and § 1985 (malicious prosecution, Brady violations, Monell, etc.).
- The district court dismissed most claims under Heck v. Humphrey, reasoning vacatur by settlement did not amount to a state-court declaration of invalidity; the Ninth Circuit majority reversed and remanded. The court left questions about enforceability of the settlement, judicial estoppel, and malicious-prosecution elements for the district court to address.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Heck bar § 1983 claims when underlying convictions were vacated pursuant to a settlement and dismissal? | Vacatur + dismissal by state court means no outstanding criminal judgment; Heck does not bar § 1983 claims. | Vacatur-by-settlement is not a state-court declaration of invalidity; plaintiffs expressly stipulated the original convictions were valid, so Heck bars the suit. | Majority: Reversed — where convictions are vacated and indictments dismissed there is no outstanding criminal judgment and Heck does not bar the § 1983 claims. |
| Is the State of Alaska an indispensable party under Rule 19? | State has not asserted an interest; complete relief can be had against City/officers. | State should be joined as an indispensable party. | Held: State not indispensable; joinder under Rule 19 not required. |
| Can defendants invoke judicial estoppel or enforce the settlement/release to dismiss claims? | Plaintiffs say the release/stipulation may be unenforceable; merits unresolved below. | Defendants assert the release/stipulation bars suit and may estop plaintiffs. | Held: District court must decide enforceability/estoppel in the first instance on remand; appellate court did not resolve. |
| Did plaintiffs adequately plead malicious prosecution/favorable termination? | Vacatur by state court satisfies Heck’s favorable-termination requirement for § 1983 malicious-prosecution claims. | Vacatur-by-settlement does not demonstrate favorable termination indicating innocence and therefore fails Heck/ malicious-prosecution element. | Held: Majority treats vacatur-by-state-court as satisfying Heck for accrual/viability; the district court should address merits (including whether favorable termination required for common-law malicious-prosecution claim) on remand. |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (establishing the favorable-termination rule for § 1983 claims that would imply invalidity of a conviction)
- Rosales-Martinez v. Palmer, 753 F.3d 890 (9th Cir. 2014) (vacatur pursuant to settlement treated, for accrual/Heck purposes, as invalidating convictions in that circuit context)
- Taylor v. County of Pima, 913 F.3d 930 (9th Cir. 2019) (holding vacatur of an earlier conviction removes Heck bar as to that vacated judgment; a later valid judgment may still bar incarceration-related damages)
- McDonough v. Smith, 139 S. Ct. 2149 (2019) (discussing accrual and the concept of an “outstanding criminal judgment” in § 1983 contexts)
- Town of Newton v. Rumery, 480 U.S. 386 (1987) (release–dismissal agreements: enforceability requires case-by-case inquiry into voluntariness and public interest)
- Wallace v. Kato, 549 U.S. 384 (2007) (accrual principles where civil claims relate to extant criminal prosecutions)