(PC) Melger v. Wesp, 2:16-cv-01103

Pro se state prisoner Melger filed a § 1983 suit against the Placer County District Attorney’s Office and individual prosecutors, alleging Brady violations and a municipal failure-to-train theory.
Melger amended his complaint twice and clarified he was not directly challenging his sentence length but complained that nondisclosure of evidence (a purported greater offense) affected the underlying conviction.
He alleges the DA’s office was deliberately indifferent to training prosecutors about Brady disclosure, invoking Canton’s “policy of inaction” theory.
Melger contends disclosure of the greater offense (Cal. Penal Code §§ 476/473(b)) would have reduced the charged offense and changed his criminal-case outcome.
The court screened the second amended complaint under 28 U.S.C. § 1915A and concluded success on Melger’s § 1983 claim would necessarily imply the invalidity of his conviction.
The court dismissed the complaint without prejudice as barred by Heck v. Humphrey and denied Melger’s motion for reconsideration of a discovery denial as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the DA office can be liable under § 1983 for failure to train re: Brady material	Melger: DA’s deliberate indifference to training caused Brady violations; single-incident liability applies	DA: Single Brady error cannot establish municipal failure-to-train; Heck bar applies because success would invalidate conviction	Dismissed: failure-to-train claim barred by Heck; Connick/Canton foreclose single-incident liability here
Whether success on the § 1983 claim would imply invalidity of conviction	Melger: nondisclosure would have reduced charged offense and changed outcome	DA: Plaintiff must first invalidate conviction via habeas before pursuing § 1983	Held: Claim would necessarily imply invalidity; Heck bars action until conviction is invalidated
Whether Connick v. Thompson permits municipal liability on single Brady incident	Melger: relies on Connick to support his failure-to-train claim	DA: Connick rejects single-incident municipal liability for prosecutors’ Brady errors	Held: Connick undercuts plaintiff’s theory; failure-to-train claim on single-incident basis is unavailing
Whether leave to amend should be granted	Melger: pro se status favors leave to amend	Court/DA: Heck defect is incurable absent habeas relief, rendering amendment futile	Held: Dismissal without leave to amend (but without prejudice) because amendment would be futile under Heck

Heck v. Humphrey, 512 U.S. 477 (bars § 1983 suit that would necessarily imply invalidity of conviction)
Connick v. Thompson, 563 U.S. 51 (municipal liability for Brady failures cannot be premised on a single-incident theory)
Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train; narrow single-incident hypothetical)
Chapman v. California, 386 U.S. 18 (harmless-error standard for constitutional errors in criminal trials)
Wilkinson v. Dotson, 544 U.S. 74 (scope of habeas v. § 1983 where relief would affect duration or validity of confinement)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Rule 8 pleading standard)
Erickson v. Pardus, 551 U.S. 89 (pro se complaint pleading standards)
Neitzke v. Williams, 490 U.S. 319 (definition of legally frivolous)
Lopez v. Smith, 203 F.3d 1122 (9th Cir. en banc; leave to amend pro se complaints)