RYALS v. MONTGOMERY COUNTY, 2:12-cv-05439

Ryals, a state prisoner, sues multiple county and state actors under §1983 for alleged false arrest, false imprisonment, and malicious prosecution stemming from a 2008 arrest.
Alleged forged affidavit of probable cause was not signed by a magistrate and allegedly altered by Detective Kropp; plaintiff claims he alerted counsel Breidenbach prior to trial.
Plaintiff alleges prosecutorial misconduct by Prince Holloway and alleges that Judge Paul Tressler failed to investigate the alleged forgery during his 2010 trial proceedings.
Plaintiff maintains the affi davit forgery invalidated his conviction, seeking investigation, sentence dismissal, damages, and attorney sanctions.
The complaint asserts the defendants acted in concert in the alleged constitutional violations, with various defendants named in the caption and on the second page of the complaint.
The court grants leave to proceed in forma pauperis but dismisses the complaint under 28 U.S.C. §1915(e)(2)(B) as frivolous or for failure to state a claim and based on abstention from seeking release already tied to a state criminal conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §1983 claims are cognizable for challenges to a conviction	Ryals argues constitutional violations occurred in his prosecution	Defendants contend Heck bar governs damages tied to underlying conviction	Claims barred by Heck; cannot obtain relief under §1983
Whether defendants enjoy absolute immunity from §1983 claims	Ryals alleges misconduct by prosecutors and judge	Prosecutors and judge entitled to absolute immunity for acts in judicial process	Judicial and prosecutorial immunity bars claims against Tressler, Holloway, Palladino; Breidenbach not a state actor
Whether the false arrest/false imprisonment claims are time-barred	Ryals asserts timely discovery of false arrest facts	Claims accrued by mid-2010; filed 2012, outside Pennsylvania two-year limit	Time-barred under Pennsylvania statute of limitations and prison mailbox rule
Whether plaintiff adequately pleaded state-action basis for §1983 claims	Claims against county and district attorney arise from official actions	Attorney Breidenbach is not a state actor; others shielded by immunity	Barred; Breidenbach not a state actor; immunity applies to prosecutorial and judicial conduct

Hess v. City of New York, — (—) (not included as not cited in the provided text)
Heck v. Humphrey, 512 U.S. 477 (1994) (§1983 damages require conviction reversal or expungement)
Imbler v. Pactman, 424 U.S. 409 (1976) (prosecutorial immunity shields from §1983 claims)
Gallas v. Supreme Court of Pa., 211 F.3d 760 (3d Cir. 2000) (judicial immunity for monetary damages in judicial acts)
Wallace v. Kato, 549 U.S. 384 (2007) (limitations period for §1983 personal injury actions (state law))
Sameric Corp. v. City of Phila., 142 F.3d 582 (3d Cir. 1998) (limitations accrual and discovery in §1983 actions)
Tourscher v. McCullough, 184 F.3d 236 (3d Cir. 1999) (standard for 12(b)(6) dismissal in §1983 actions)
Buck v. Hampton Twp. Sch. Dist., 452 F.3d 256 (3d Cir. 2006) (pro se pleadings liberal construction; frivolousness analysis under §1915)