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Padilla v. Mann
1:18-cv-01175
| D.N.M. | Feb 13, 2020
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Background

  • Plaintiff Danny A. Padilla, a state prisoner serving ~10.5 years for trafficking, DWI (7th), and tampering, filed a Tort Complaint in New Mexico state court alleging unconstitutional stop/frisk by Patrolman Michael Mann and an unconstitutional strip/clothing search by County Tech Judson Davis that produced a bag testing positive for methamphetamine.
  • Padilla claimed violations of the 4th, 5th, 8th Amendments and New Mexico constitutional provisions and sought dismissal of state criminal charges, immediate release, and substantial per‑day damages.
  • Defendant Mann removed the case to federal court; the matter was screened under 28 U.S.C. § 1915A and Rule 12(b)(6).
  • The district court concluded a favorable federal ruling would necessarily invalidate Padilla’s state conviction and applied the Heck doctrine to bar the federal civil‑rights claims.
  • The court dismissed all federal claims with prejudice, denied leave to amend as futile, declined supplemental jurisdiction over state claims, remanded the state claims to Union County Eighth Judicial District Court, and denied pending motions as moot.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Padilla may bring § 1983/due process/constitutional claims based on alleged illegal search/arrest that led to his conviction Padilla argues the stop/frisk and booking searches were illegal and caused his prosecution/conviction; seeks dismissal of charges, release, and damages Removal implied federal jurisdiction; defendants moved for judgment on pleadings Dismissed under Heck: § 1983 claims barred because success would imply invalidity of the state conviction
Whether the court should permit amendment of the complaint Padilla should be allowed to cure pleading defects as a pro se litigant Defendants argue claims are legally barred Amendment denied as futile because Heck would continue to bar the claims
Whether the court should exercise supplemental jurisdiction over state‑law claims Padilla asserts claims under New Mexico Tort Claims Act and state constitution Defendants relied on federal removal; court must decide whether to keep state claims after dismissing federal claims Court declined supplemental jurisdiction and remanded state claims to state court
Disposition of pending motions (motions for judgment on the pleadings; motion for extension) Padilla sought extension/time; defendants sought judgment on pleadings Motions pending before district court All pending motions denied as moot in light of dismissal/remand

Key Cases Cited

  • Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claim that would imply invalidity of conviction must be dismissed)
  • Wilkinson v. Dotson, 544 U.S. 74 (2005) (prospective relief barred when it would necessarily invalidate conviction)
  • Edwards v. Balisok, 520 U.S. 641 (1997) (same principle applying to certain prison‑disciplinary challenges)
  • Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard; plausible claim requirement)
  • United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (comity and avoidance of needless state‑law decisions)
  • Osborn v. Haley, 549 U.S. 225 (2007) (discretion to decline supplemental jurisdiction after federal claims dismissed)
  • Beck v. City of Muskogee Police Dept., 195 F.3d 553 (10th Cir. 1999) (application of Heck in the Tenth Circuit)
Read the full case

Case Details

Case Name: Padilla v. Mann
Court Name: District Court, D. New Mexico
Date Published: Feb 13, 2020
Docket Number: 1:18-cv-01175
Court Abbreviation: D.N.M.