Wanton v. Prichard, 1:16-cv-01136

Plaintiff Raul Wanton, a state prisoner proceeding pro se and in forma pauperis, sued his former court‑appointed attorneys (Troy Wayne Prichard and Raul A. Lopez) and “all other officers of the court,” alleging ineffective assistance, collusion with the district attorney, and coercion into a guilty plea.
Wanton sought money damages, immediate release from custody, disbarment of his attorneys, and criminal charges against them.
The Court screened the complaint sua sponte under 28 U.S.C. §§ 1915(e)(2) and 1915A because Wanton is a prisoner proceeding in forma pauperis.
The complaint contained conclusory allegations of a conspiracy between defense counsel and prosecutors but no factual allegations showing an agreement or concerted action.
The Court found many defendants (judges, prosecutors, and court officers) entitled to absolute immunity; claims implying invalidity of Wanton’s conviction were barred by Heck v. Humphrey; and requests to disbar attorneys or initiate criminal prosecutions were beyond the court’s authority.
The complaint was dismissed without prejudice as frivolous under §§ 1915(e)(2)(B)(i) and 1915A(b)(1); a PLRA strike was assessed under 28 U.S.C. § 1915(g).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wanton stated a § 1983 claim against his court‑appointed attorneys	Attorneys provided ineffective assistance, colluded with DA, and coerced a plea	Attorneys are private actors doing traditional lawyer functions and thus not state actors	Dismissed: bare conspiracy assertions lack factual support; no state action shown
Whether allegations against judges/prosecutors/court staff can proceed	Included as “all other officers of the court” liable for conduct in case	Judges, prosecutors, and court officers are absolutely immune for judicial/prosecutorial acts	Dismissed as frivolous: claims against immune officials barred
Whether § 1983 damages claims are cognizable while conviction stands (Heck bar)	Seeks damages and release based on events tied to conviction	A § 1983 claim that would imply invalidity of conviction is barred until conviction is invalidated	Dismissed without prejudice under Heck; plaintiff may refile if conviction invalidated
Whether court can order disbarment/criminal prosecution or grant immediate release in § 1983 case	Requests disbarment of attorneys, criminal charges, and immediate release	Court lacks authority to disbar (state disciplinary bodies) and to direct prosecutions; habeas, not § 1983, is proper vehicle for release	Court lacks power to grant disbarment/prosecutions; release claim improper in § 1983 (must seek habeas)

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard: factual content must permit reasonable inference of liability)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim)
Heck v. Humphrey, 512 U.S. 477 (§ 1983 claim barred if success would imply invalidity of conviction/sentence)
Polk County v. Dodson, 454 U.S. 312 (public defenders generally not state actors for § 1983 purposes)
Tower v. Glover, 467 U.S. 914 (private counsel acts under color of state law only when conspiring with state officials)
Stump v. Sparkman, 435 U.S. 349 (judicial absolute immunity for judicial acts)
Imbler v. Pachtman, 424 U.S. 409 (prosecutorial absolute immunity for initiating/prosecuting criminal actions)
Preiser v. Rodriguez, 411 U.S. 475 (challenges to conviction/duration of confinement must proceed via habeas corpus)
Kay v. Bemis, 500 F.3d 1214 (pro se complaints are construed liberally; but dismissal proper when amendment would be futile)
Hafed v. Federal Bureau of Prisons, 635 F.3d 1172 (dismissal as frivolous or for failure to state a claim counts as a PLRA strike)