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Delaware Federal Court Examines Requirements for Civil Rights Claims Against Judges, Prosecutors, and Defense Attorneys
Sye Christopher-Rashaud Newton v. City of Wilmington, et al.
Sye Christopher-Rashaud Newton v. City of Wilmington, et al. involved the United States District Court for the District of Delaware’s screening of an inmate’s civil rights lawsuit against the judges, prosecutors, and other individuals involved in two (2) criminal cases against the inmate, pursuant to the screening provisions of 28 U.S.C. § 1915(e)(2)(B) and § 1915A(b). The Court concluded that the inmate’s claims were barred by judicial immunity, prosecutorial immunity, or otherwise lacked an arguable basis in law and fact. Thus, the Court dismissed the inmate’s complaint as frivolous.
By way of factual background, on November 9, 2015, Plaintiff Sye Christopher-Rashaud Newton (“Plaintiff”), an inmate at the James T. Vaughn Correctional Center, filed a complaint in the United States District Court for the District of Delaware against a number of private attorneys, public defenders, judges, the Attorney General of the State of Delaware, deputy attorneys general, and the City of Wilmington, Delaware. Plaintiff filed the complaint pursuant to 42 U.S.C. § 1983, claiming violations of his constitutional rights arising from two (2) criminal cases wherein Plaintiff entered into plea agreements. Plaintiff alleged that he was coerced into entering into both plea agreements through the use of threats, fraudulent information, and misadvice—all accomplished through conspiratorial actions among the defendants. Plaintiff pled guilty to second degree assault in October 2006, and pled guilty to robbery on February 27, 2007, following which he was immediately sentenced in both the assault and robbery cases.
Plaintiff complained about the representation he received from his defense counsel, actions taken by deputy attorneys general in prosecuting his cases, orders entered by judges, and orders filed under wrong case numbers and sent to wrong parties. Plaintiff alleged these acts violated his civil rights because he was African American and indigent. Plaintiff sought punitive damages and declaratory and injunctive relief including an investigation of the Delaware criminal justice system.
As Plaintiff was pro se and had been granted in forma pauperis status, the Court explained that it could properly dismiss Plaintiff’s complaint sua sponte under the screening provisions of 28 U.S.C. § 1915(e)(2)(B) and § 1915A(b) if “the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief.” See Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions); 28 U.S.C. § 1915A (actions in which prisoner seeks redress from a governmental defendant); 42 U.S.C. § 1997e (prisoner actions brought with respect to prison conditions). The Court explained that an action is frivolous if it “lacks an arguable basis either in law or in fact,” and that the Court may dismiss a complaint as frivolous if it is “based on an indisputably meritless legal theory” or a “clearly baseless” or “fantastic or delusional” factual scenario. See Neitzke v. Williams, 490 U.S. 319, 325-28 (1989); Wilson v. Rackmill, 878 F.2d 772, 774 (3d Cir. 1989); Deutsch v. United States, 67 F.3d 1080, 1091-92 (3d Cir. 1995).
First, regarding Plaintiff’s claims against judges for actions taken by them during the pendency of Plaintiff’s criminal cases, the Court noted that “a judicial officer in the performance of his duties has absolute immunity from suit and will not be liable for his judicial acts.” See Capogrosso v. The Supreme Court of New Jersey, 588 F.3d 180, 184 (3d Cir. 2009) (quoting Azubuko v. Royal, 443 F.3d 302, 303 (3d Cir. 2006)). Thus, the Court dismissed those claims against the defendant judges on the basis of judicial immunity.
Second, regarding Plaintiff’s claims against the deputy attorneys general for their actions during the prosecution of his criminal cases, the Court noted that prosecutors acting within the scope of their duties in initiating and pursuing a criminal prosecution are immune to suit under § 1983, and that the acts of which Plaintiff complained “fit squarely within the realm of official prosecutorial duties.” See Imbler v. Pachtman, 424 U.S. 409, 410 (1976); Odd v. Malone, 538 F.3d 202, 208 (3d Cir. 2008). Thus, the Court dismissed those claims against the prosecutor defendants on the basis of prosecutorial immunity.
Third, regarding Plaintiff’s claims against the Attorney General of the State of Delaware, Matt Denn, the Court noted that Denn was named as a defendant based upon his supervisory position. The Court explained, however, that it was “well established that claims based solely on the theory of respondeat superior or supervisor liability are facially deficient.” See, e.g., Solan v. Ranck, 326 F.App’x 97, 100-01 (3d Cir. 2009) (unpublished) (holding that “a defendant in a civil rights action must have personal involvement in the alleged wrongs; liability cannot be predicated solely on the operation of respondeat superior”). Thus, the Court dismissed the claims against Denn as frivolous.
Next, the Court noted that the complaint named private attorneys, an assistant public defender, and the Delaware Public Defender as defendants. The Court concluded, however, that none of these individuals were “state actors as is required to state a claim under § 1983.” See Polk Cnty. v. Dodson, 454 U.S. 312, 325 (1981) (holding that public defenders do not act under color of state law); Steward v. Meeker, 459 F.2d 669 (3d Cir. 1972) (privately-retained counsel does not act under color of state law when representing client); Thomas v. Howard, 455 F.2d 228 (3d Cir. 1972) (court-appointed attorney does not act under color of state law). Thus, the Court dismissed the claims against those defendants as frivolous.
Finally, regarding Plaintiff’s claim against the City of Wilmington, the Court explained that a municipality may only be held liable under § 1983 when the “execution of a government’s policy or custom… inflicts the injury.” See Andrews v. City of Philadelphia, 895 F.2d 1469, 1480 (3d Cir. 1990). The Court found, however, that Plaintiff had not alleged that a custom or policy established by the City of Wilmington caused him harm, and thus, that his § 1983 claim could not stand. Therefore, the Court dismissed the claim against the City of Wilmington as frivolous.
For the above reasons, the Court dismissed Plaintiff’s complaint as frivolous and based upon defendants’ immunity.
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