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Keywords

plaintiffdefendantdamageshearingsummary judgmentparole
plaintiffdefendantdamagesappealtestimonymotionhabeas corpusleaseparole

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Quintana v. Gates, Not Reported in F.Supp.2d, 2004 WL 1661540

Facts

Martin Quintana was arrested by LAPD officers on January 12, 2000, while on parole for a prior drug conviction. The officers claimed that Quintana interfered with their surveillance of a gang by whistling, which led to his arrest and subsequent parole hold. Quintana contended that he was merely visiting a girlfriend and denied the officers' claims about his behavior and condition at the time of the arrest. Following a hearing, his parole was revoked for ten months based on charges including interfering with police duties.

Plaintiff Martin Quintana was sentenced on June 21, 1996 for possession/purchase of cocaine for sale. He received four years in state prison and, after serving a portion of his four-year sentence, was released to a three-year parole period on August 9, 1998.

Issue

Whether Quintana's § 1983 claims are barred by the Heck v. Humphrey doctrine, which requires that a conviction or sentence be invalidated before a plaintiff can pursue damages for alleged constitutional violations related to that conviction or sentence.

Defendants argue that Heck v. Humphrey, 512 U.S. 477 (1994) bars Plaintiff's § 1983 claims, and that Plaintiff does not have standing to assert a claim for injunctive relief.

Rule

Under Heck v. Humphrey, a plaintiff cannot bring a § 1983 action for damages that would imply the invalidity of a conviction or sentence unless that conviction or sentence has been reversed, expunged, or declared invalid.

The Court held that: in order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court's issuance of a writ of habeas corpus.

Analysis

The court determined that Quintana's claims of false arrest and framing by the police officers were directly related to the validity of his parole revocation. Since the evidence supporting his claims was the same as that which led to his parole revocation, a ruling in his favor would necessarily imply that the revocation was invalid. Therefore, under the Heck doctrine, Quintana's claims could not proceed without first overturning the parole revocation.

The evidence presented to the BPT-the officers' testimony that Quintana interfered with their surveillance by whistling and Quintana's testimony that the officers were lying in order to frame him-is the same evidence that would be presented in this case with respect to Quintana's claim that he was falsely arrested and framed.

Conclusion

The court granted summary judgment for the defendants, concluding that Quintana's § 1983 claims were barred by the Heck doctrine because he had not invalidated his parole revocation.

Therefore, the Heck doctrine bars Quintana's § 1983 claims.

Who won?

Defendants (City of Los Angeles and LAPD officers) prevailed because the court found that Quintana's claims were barred by the Heck doctrine, which requires a prior invalidation of the underlying conviction or sentence.

Defendants' motion is GRANTED.

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