MOLINA-AVILES v. District of Columbia
2011 U.S. Dist. LEXIS 66670
D.D.C.2011Background
- Twenty plaintiffs sue the District of Columbia and Officer King under 42 U.S.C. §1983 alleging wrongful DWI convictions based on allegedly unreliable blood alcohol readings from calibrations of the Intoxilyzer 5000EN.
- Convictions hinge on BAC results at or above .08 g/210 L; a District announcement (Feb. 26, 2010) suggested calibrations made readings up to ~30% too high.
- Plaintiffs pursue five §1983 claims: substantive due process (two variations), exculpatory-material withholding, and Eighth Amendment cruel and unusual punishment, directed at King in his individual capacity for at least one claim.
- Procedural posture included a court-ordered status updates, a stay, and later a split update: most plaintiffs had pled guilty; some moved to withdraw pleas or contest convictions, with limited favorable terminations by mid-2011.
- Court analyzes Heck v. Humphrey and Spencer v. Kemna to determine whether §1983 suits may proceed despite non-favorable termination, and concludes DC habeas-type remedies undermine Spencer and binding Heck controls; sixteen plaintiffs lack favorable terminations, so claims are dismissed without prejudice, while four plaintiffs with favorable termination may proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Heck precludes §1983 claims challenging convictions not favorably terminated | Plaintiffs rely on Spencer to avoid Heck's favorable termination rule | Heck controls; Spencer exception not binding | Heck precludes these suits; Spencer not binding |
| Whether Spencer exception applies when habeas relief is unavailable | Spencer should apply where habeas-like relief is not available | Habeas-type relief exists in DC; Spencer not applicable | Spencer exception not applicable; DC has remedies |
| Whether DC habeas-type remedies render Spencer inapplicable | DC provides avenues to vacate convictions (e.g., Rule 32(e)) | Remedies exist and undermine Spencer rationale | DC remedies available; Spencer inapplicable |
| Which plaintiffs may continue in the §1983 action | All plaintiffs’ claims should proceed if underlying convictions invalidated | Only plaintiffs with favorable termination may proceed | Sixteen dismissed without prejudice; four may proceed (favorable terminations) |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (favorable-termination requirement for §1983 challenges to criminal judgments)
- Spencer v. Kemna, 523 U.S. 1 (U.S. 1998) (concurring view on exceptions when habeas relief unavailable)
- Snell v. United States, 754 A.2d 289 (D.C.2000) (‘in custody’ concept for §23-110 habeas relief in DC)
- Jones v. Cunningham, 371 U.S. 236 (U.S. 1963) (federal habeas-like concepts; custody status)
- Beamer v. Baars (Aleotti v. Baars cited), 896 F.Supp. 1 (D.D.C.1995) (earlier treatment of Heck/Spencer dynamics)