Reginald Eugene Grimes, Sr. v. Security Manager Lidia Sabri, 674 F. App'x 860

Reginald Grimes, a federal prisoner, sued Avis Budget Group and four Avis employees under 42 U.S.C. § 1983 after federal authorities used information (allegedly obtained from Avis) in a drug investigation that led to his conviction.
Grimes alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights and sought compensatory and punitive damages and attorney’s fees.
His criminal case resulted in conviction on two felony drug counts; his motion to suppress evidence (including cell phones) was denied during the criminal proceedings.
Grimes filed the § 1983 complaint one month after conviction; the magistrate judge recommended dismissal under 28 U.S.C. § 1915(e)(2)(B) as an impermissible collateral attack under Heck v. Humphrey.
The district court dismissed the complaint with prejudice, alternatively concluding Grimes failed to allege facts plausibly showing the private defendants acted under color of state law; Grimes appealed only the state-action ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether private Avis employees acted "under color of state law" for § 1983	Grimes: Avis employees assisted law enforcement in searches/seizures and therefore are state actors	Avis: Private employees; Grimes failed to plead facts showing state action under any test	Court: Dismissed — complaint lacked plausible facts showing state action
Whether complaint improperly attacks conviction under Heck	Grimes: sought civil relief for alleged constitutional violations arising from investigation	Defendants: dismissal appropriate if lawsuit would imply invalidity of conviction	Court: Did not reach Heck analysis on appeal; district court had relied on it but appeal limited to state-action issue
Whether pro se status warrants lenient pleading treatment	Grimes: pro se pleadings should be construed liberally	Defendants: court not required to rewrite deficient pleadings	Court: Applied liberal construction but still required plausible factual allegations; dismissal proper
Whether dismissal with prejudice (no leave to amend) was appropriate	Grimes: appealed dismissal	Defendants: amendment would be futile	Court: Affirmed dismissal with prejudice because amendment would be futile

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain sufficient factual matter to be plausible)
Heck v. Humphrey, 512 U.S. 477 (1994) (civil suit implying invalidity of conviction barred until conviction reversed)
Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) (Bivens provides remedy for federal-officer constitutional violations)
Focus on the Family v. Pinellas Suncoast Transit Auth., 344 F.3d 1263 (11th Cir. 2003) (tests for private-party state action)
Harvey v. Harvey, 949 F.2d 1127 (11th Cir. 1992) (private actors are state actors only in rare circumstances)
Arrington v. Cobb Cty., 139 F.3d 865 (11th Cir. 1998) (§ 1983 requires both constitutional deprivation and action under color of state law)
Farese v. Scherer, 342 F.3d 1223 (11th Cir. 2003) (standard of review for § 1915(e)(2)(B) dismissals)
Alba v. Montford, 517 F.3d 1249 (11th Cir. 2008) (pro se pleadings construed liberally)
GJR Investments, Inc. v. County of Escambia, 132 F.3d 1359 (11th Cir. 1998) (court will not rewrite deficient pro se pleadings)
Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (failure to address alternative district-court holdings is abandonment)
Bryant v. Dupree, 252 F.3d 1161 (11th Cir. 2001) (dismissal with prejudice without leave to amend is appropriate if amendment would be futile)