Romancorrea v. Superior Court of California, County of Riverside, 1:20-cv-00242-JLT-HBK

Plaintiff Antonio Romancorrea, a state prisoner proceeding pro se, filed a § 1983-style civil rights complaint alleging his conviction and sentence are unlawful and seeking relief for incarceration for a crime he says he did not commit.
The court observed that challenges to the fact or duration of confinement are normally brought via habeas corpus and that Heck v. Humphrey bars § 1983 claims that would imply the invalidity of a conviction unless the conviction has been invalidated.
The court ordered Romancorrea to show cause within 30 days why his central claim of illegal incarceration should not be dismissed under Heck by demonstrating that his underlying conviction has been invalidated.
The court informed plaintiff that, instead of this lawsuit, he may file a § 2254 habeas petition in federal court but must first exhaust state-court remedies as required by § 2254(b)(1)(A); the clerk was ordered to send a habeas application form.
Plaintiff also alleged limited law library access, facility leaks, and unsafe/unsanitary kitchen conditions; the court found those allegations, as pleaded, insufficient because they fail to identify defendants or state plausible § 1983 claims.
The court gave plaintiff the alternative to file an amended complaint focused on actionable prison-condition claims (which would supersede the original complaint) and warned that failure to comply may result in dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a § 1983 suit challenging conviction/sentence is barred by Heck	Romancorrea contends his conviction and sentence are unlawful and seeks relief for wrongful incarceration	Not asserted in the record; court applied established Heck rule sua sponte	Court ordered plaintiff to show his conviction has been invalidated or the claim will be dismissed under Heck
Whether plaintiff should pursue habeas instead and exhaustion requirement	Plaintiff seeks federal relief for wrongful conviction; implied preference for federal forum	Not asserted; court noted statutory exhaustion requirement for § 2254 petitions	Court advised filing a § 2254 habeas petition and noted § 2254(b)(1)(A) exhaustion requirement; clerk to provide habeas form
Whether pleaded prison-condition claims state actionable § 1983 claims	Plaintiff alleges limited law library access, facility leaks, and dirty/slippery kitchen	Not raised by defendants; court reviewed sufficiency under Rule 8/Twombly/Iqbal	Court found those allegations insufficiently pleaded (no identified defendants, implausible facts); ordered amended complaint if plaintiff wishes to pursue such claims

Heck v. Humphrey, 512 U.S. 477 (1994) (favorable-termination rule bars § 1983 claims that would imply invalidity of a conviction)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions insufficient to state a claim)
Soo Park v. Thompson, 851 F.3d 910 (9th Cir. 2017) (elements for § 1983 causation and state-action analysis)
Kobold v. Good Samaritan Reg'l Med. Ctr., 832 F.3d 1024 (9th Cir. 2016) (complaint need not identify precise legal theory but must state a claim)
Nagrampa v. MailCoups, Inc., 469 F.3d 1257 (9th Cir. 2006) (definition of a "claim" as enforceable right to relief)
Lacey v. Maricopa County, 693 F.3d 896 (9th Cir. 2012) (amended complaint supersedes prior pleadings)