Quartman v. State of Wisconsin Department of Corrections, 2:22-cv-01015

Pro se plaintiff Qianna Quartman filed an amended § 1983 complaint after release from prison, alleging constitutional violations arising from a 2019 parole revocation hearing and later actions by parole agents.
Quartman alleges she attended a revocation hearing while on oxycodone post‑C‑section and postpartum depression; her husband (a key witness) was not subpoenaed and certain DOC documents and unsigned statements were relied on.
She alleges Agent Priebe issued a no‑contact order, coerced her husband to give a statement, and later (without her consent) permitted her children to relocate to Illinois, resulting in loss of custody and family disruption.
As a result of the hearing, Quartman was revoked and returned to prison for 2.5 years; she seeks damages under § 1983 for the alleged misconduct.
The court granted Quartman leave to proceed in forma pauperis, screened the amended complaint under 28 U.S.C. § 1915(e)(2)(B), and dismissed the action: revocation‑related claims without prejudice as Heck‑barred; child‑custody claims with prejudice as factually frivolous; denied leave to further amend as futile.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1983 damages claims attacking the parole revocation are cognizable	Quartman contends the hearing was unconstitutional and led to wrongful revocation and imprisonment	Defendants (and court) assert relief would imply invalidity of the revocation and is barred unless conviction reversed	Dismissed without prejudice under Heck v. Humphrey (Heck‑barred)
Whether allegations that Agent Priebe authorized child relocation state a viable claim	Quartman alleges Priebe permitted children to move to Illinois and interfered with parental rights	Defendants argue parole agents lack authority for child‑custody transfers; facts implausible	Dismissed with prejudice as factually frivolous
Whether court should permit another amendment	Quartman had opportunity to allege facts; seeks relief on merits	Defendants opposed; court evaluated futility	Leave to amend denied as futile; action dismissed

Heck v. Humphrey, 512 U.S. 477 (1994) (damages claim that would imply invalidity of conviction/sentence is barred unless conviction reversed or set aside)
Knowlin v. Thompson, 207 F.3d 907 (7th Cir. 2000) (Heck applies to parole/probation revocations)
Savory v. Cannon, 947 F.3d 409 (7th Cir. 2020) (Heck controls outcome where § 1983 claim implies invalidity of conviction regardless of habeas availability)
Denton v. Hernandez, 504 U.S. 25 (1992) (definition of frivolous claims under § 1915)
Felton v. City of Chicago, 827 F.3d 632 (7th Cir. 2016) (examples of factually frivolous allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleading)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not accepted as true for pleading purposes)
Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) (courts need not accept threadbare recitals of elements)
Runnion ex rel. Runnion v. Girl Scouts of Greater Chi. & Nw. Ind., 786 F.3d 510 (7th Cir. 2015) (leave to amend may be denied as futile)
Perez v. Fenoglio, 792 F.3d 768 (7th Cir. 2015) (same)