Quintez Talley v. Commonwealth of Pennsylvania
22-3337
3rd Cir.Mar 21, 2025Background
- Quintez Talley, a pro se Pennsylvania state prisoner, was convicted in 2021 for arson after setting fire to his prison cell.
- After his conviction, Talley filed a civil suit in federal court against various state entities and officials, alleging constitutional and federal statutory violations stemming from the investigation and prosecution of his case.
- He attempted to bring the suit on behalf of himself and "Pennsylvanians with Mental Illness," asserting violations of due process, use of false evidence, and discrimination under the ADA and RA.
- The District Court adopted a Magistrate Judge's recommendation to dismiss the complaint, finding Talley could not represent others, his claims were barred by doctrine or failed to state a claim, and declining to retain jurisdiction over state claims.
- Talley appealed, but the Third Circuit summarily affirmed the District Court’s dismissal, finding no substantial issue raised on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to represent others | Talley could represent "Pennsylvanians with Mental Illness" in addition to himself. | Non-lawyer pro se litigants cannot represent others. | Talley, as a non-lawyer, cannot represent others. |
| Constitutional claims relating to conviction | Conviction unconstitutional—no probable cause and due process violations during trial. | Claims challenge validity of conviction, which is not permitted via civil action. | Claims barred by Heck v. Humphrey as they would impugn the conviction. |
| ADA and RA discrimination due to mental illness | State actors discriminated based on his mental illness during prosecution and trial. | Complaint alleges only conclusory, not factual, discrimination. | Insufficient facts alleged to support ADA or RA violations. |
| Jurisdiction over state law claims | State law claims included in the complaint. | Once federal claims dismissed, court should not keep state claims. | District Court properly declined supplemental jurisdiction over state law claims. |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (precludes civil rights claims that would undermine the validity of a criminal conviction)
- Collinsgru v. Palmyra Bd. of Educ., 161 F.3d 225 (3d Cir. 1998) (non-lawyers may not represent others in federal court; abrogated on a different issue)
- Hedges v. Musco, 204 F.3d 109 (3d Cir. 2000) (declining supplemental jurisdiction over state law claims after dismissal of all federal claims)