Mathis v. Angeli, 1:25-cv-00209

Bryan Mathis, a federal prisoner, filed a civil suit pro se against two Assistant U.S. Attorneys, a federal judge, and a local detective, alleging constitutional rights violations related to his conviction.
Mathis was convicted of unlawful firearm possession and marijuana distribution, and his conviction was upheld on appeal.
Mathis claims law enforcement fabricated evidence, conducted illegal searches, and the prosecutors and judge allowed false evidence at trial.
He raised Bivens claims (against federal officials) and § 1983 claims (against the local detective), seeking $10 million in damages for injuries stemming from his imprisonment.
Mathis also moved to proceed in forma pauperis, which the court granted, but then screened and dismissed his complaint.
The court reviewed the complaint under statutory screening requirements for frivolity and immunity, ultimately dismissing the claims based on Heck v. Humphrey and immunity doctrines.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of Conviction-Related Claims	Mathis's constitutional rights were violated, invalidating his conviction.	Claims challenge conviction; barred by law	Barred by Heck v. Humphrey; must be reversed first.
Prosecutorial Immunity	AUSAs allowed false evidence and testimony, conspiring in his conviction.	Prosecutors are immune for trial actions	Absolute immunity for conduct during criminal prosecution.
Judicial Immunity	Judge knowingly allowed constitutional violations in the trial.	Judges are immune from civil suit	Judge Gaughan immune; dismissed with prejudice.
Local Detective § 1983 Claim	Detective Alcantara fabricated evidence and caused false imprisonment.	Success would imply conviction invalid	Dismissed without prejudice under Heck.

Heck v. Humphrey, 512 U.S. 477 (1994) (bars § 1983 damages claims that would imply conviction/sentence invalidity unless conviction is reversed or otherwise invalidated)
Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutors have absolute immunity for actions associated with judicial phase of criminal process)
Mireles v. Waco, 502 U.S. 9 (1991) (judges are immune from suit based on judicial acts taken in their official capacity)