Morales v. Grant County Commissioners, 1:20-cv-00197

Plaintiff Martin Morales, a pro se prisoner, filed a 42 U.S.C. § 1983 suit alleging wrongful conviction and illegal imprisonment arising from his arrest and criminal trial.
He asserted three claims: (1) he was prevented from cross-examining witnesses at trial; (2) chain-of-custody issues with drug evidence; and (3) the arrest warrant was improper/illegal.
The court screened the complaint under 28 U.S.C. § 1915A and noted Morales’ separate habeas petition (still pending).
The court held the first two claims are barred by Heck v. Humphrey because success would necessarily imply the invalidity of the conviction, which has not been vacated.
The Fourth Amendment arrest-warrant claim may be cognizable under § 1983 even if the conviction stands, but the complaint lacked factual detail and did not show any defendant’s personal involvement; municipal liability requires a policy/custom connection.
The court granted Morales leave to amend by April 30, 2021, and warned that failure to amend would result in dismissal under § 1915A.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Denial of cross-examination at trial (due process)	Morales contends he was not allowed to cross-examine witnesses, depriving him of a fair trial	(Implicit) defendants not directly addressed; conviction stands	Claim barred by Heck because success would call conviction into question; must proceed via habeas unless conviction vacated
2. Chain-of-custody/evidence issues	Morales alleges improper handling/presentation of drug evidence at trial	(Implicit) same as above	Claim barred by Heck for same reason as Issue 1
3. Illegal arrest/warrant (Fourth Amendment)	Morales alleges arrest was improper and warrant invalid	Defendants lack alleged personal involvement; § 1983 requires personal participation or an established policy/custom to impose municipal liability	Court cannot determine Heck applicability from complaint; claim not adequately pleaded against named defendants — needs facts showing personal involvement or municipal policy/custom
4. Pleading and remedial posture	Morales seeks relief via this § 1983 action	Court must screen under § 1915A and may allow amendment	Court grants leave to amend (by April 30, 2021); warns that failure to amend results in dismissal under § 1915A

Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 damages claim challenging conviction barred unless conviction has been invalidated)
Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (municipal liability requires an unconstitutional policy or custom)
Simpson v. Rowan, 73 F.3d 134 (7th Cir. 1995) (illegal arrest/search claim under Fourth Amendment can be pursued in § 1983 despite a subsequent conviction)
Matz v. Klota, 769 F.3d 517 (7th Cir. 2014) (§ 1983 requires personal involvement of defendant for damages)
Glisson v. Ind. Dep’t of Corr., 849 F.3d 372 (7th Cir. 2017) (Monell analysis; municipal liability focus)
Abu-Shawish v. United States, 898 F.3d 726 (7th Cir. 2018) (general rule favoring allowance of leave to amend defective pleadings)
Luevano v. Wal-Mart, 722 F.3d 1014 (7th Cir. 2013) (permitting amendment where it would not be futile)