Wilson v. State of Alabama (INMATE 1)
3:15-cv-00017
M.D. Ala.Jan 28, 2015Background
- Wilson, an inmate at Lee County Detention Center, sues under 42 U.S.C. §1983 seeking dismissal of his Lee County conviction and monetary damages.
- Defendants named are the State of Alabama, the Lee County Detention Center, and the Circuit Court of Lee County.
- Court screens complaint sua sponte for dismissal prior to service under §1915(e)(2)(B).
- Claims include allegations about jury selection and lack of Miranda warning at surrender.
- Court concludes claims against the State, detention center, and circuit court are frivolous or non-cognizable, and recommends dismissal prior to service.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State of Alabama can be sued under §1983. | Wilson maintains state liability. | Alabama is absolutely immune and not a person under §1983. | State immune; claims frivolous; dismissed. |
| Whether the Lee County Detention Center is a suable entity under §1983. | Detention center liable for constitutional violations. | Detention centers are not legal entities under §1983. | Detention Center dismissed. |
| Whether Circuit Court of Lee County is a proper defendant. | Counts against state court viable under §1983. | State courts are not persons under §1983. | Circuit Court dismissed. |
| Whether Wilson's Miranda claim is cognizable under §1983. | Miranda rights were not read; violation occurred. | Miranda claim not cognizable under §1983. | Miranda claim barred under §1983. |
| Whether Heck v. Humphrey bars §1983 challenge to conviction. | Challenge to conviction should proceed. | Civil action cannot attack conviction; must pursue habeas. | Heck bars §1983 claims; need habeas relief; dismiss accordingly. |
Key Cases Cited
- Papasan v. Allain, 478 U.S. 265 (1986) (state sovereign immunity under Eleventh Amendment; no suit absent consent)
- Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (state not a ‘person’ under §1983)
- Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous/malicious complaint dismissal standards)
- Dean v. Barber, 951 F.2d 1210 (11th Cir. 1992) (county detention centers not legal entities for §1983 liability)
- Edwards v. Balisok, 520 U.S. 641 (1997) ( Heck immutability of claims challenging validity of confinement)
- Heck v. Humphrey, 512 U.S. 477 (1994) (bar on §1983 challenge to conviction absent reversal/expungement)
- Okoro v. Callaghan, 324 F.3d 488 (7th Cir. 2003) (Heck applicability to declaratory/injunctive relief)
- Dollar v. Coweta Cnty. Sheriff’s Office, 446 F. App’x 248 (11th Cir. 2011) (Miranda claims not cognizable under §1983)
- Jones v. Cannon, 174 F.3d 1270 (11th Cir. 1999) (Miranda not cognizable under §1983)
- Balisok, 520 U.S. 645 (1997) (Heck framework for collateral attacks)