Ronald Riley v. District Attorney Dauphin
671 F. App'x 29
| 3rd Cir. | 2016Background
- Ronald Riley, a state prisoner convicted of rape in 1985, sued under 42 U.S.C. § 1983 against Dauphin County District Attorney Edward Marsico for prosecutions in 2006 under Pennsylvania’s Megan’s Law registration provisions.
- Riley alleged the Megan’s Law registration requirements did not apply to him and that Marsico misled the state court to procure Riley’s guilty plea and conviction for failing to register.
- A magistrate judge recommended dismissal for failure to state a claim; Riley objected, but the District Court adopted the recommendation and dismissed the complaint with prejudice under 28 U.S.C. § 1915A.
- Riley appealed pro se; the Court of Appeals reviews § 1915A dismissals de novo and construes pro se pleadings liberally.
- The court treated Riley’s pleadings as (1) a malicious prosecution claim challenging his 2006 conviction and (2) a Fourteenth Amendment due process claim contesting the application of Megan’s Law registration.
- The District Court dismissed with prejudice because legal deficiencies could not be cured by amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Malicious prosecution/ challenge to conviction | Riley: Marsico wrongfully prosecuted and obtained an illegitimate conviction in 2006 | Marsico: Prosecutorial acts are immune; conviction not invalidated so claim barred by Heck | Dismissed — Heck bars challenge absent prior invalidation; prosecutors absolutely immune under Imbler |
| Due process re: Megan's Law registration | Riley: He was denied adequate due process when the court determined Megan’s Law applied and required him to register | Marsico/Respondent: Prior rulings and law foreclose the claim; Riley previously litigated and lost similar claim | Dismissed — claim meritless and previously rejected by this Court |
| Leave to amend | Riley implicitly: complaint could be cured | District Court: defects go to the merits and cannot be cured | Dismissed with prejudice — court did not abuse discretion in denying leave to amend |
| Appellate standard/pleading construction | Riley: pro se filings should be liberally construed | Respondent: standard of review and precedent apply | Court: applied liberal construction but still found failure to state a claim |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claim challenging conviction barred unless conviction has been invalidated)
- Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutors have absolute immunity for actions within scope of prosecutorial duties)
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings must be liberally construed)
- Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (dismissal without leave to amend proper when defects cannot be cured)
- Allah v. Seiverling, 229 F.3d 220 (3d Cir. 2000) (de novo review standard for § 1915A dismissals akin to Rule 12(b)(6))
- Hughes v. Long, 242 F.3d 121 (3d Cir. 2001) (appellate court may affirm on any ground supported by the record)