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Eleventh Circuit rules that plaintiff’s civil rights case for false imprisonment by Sheriff’s officer was not barred by fact that underlying trespassing charge was dropped at time of his guilty plea to unrelated offenses

On December 30, 2019, in Henley v. Payne, No. 18-13101, the Eleventh Circuit Court of Appeals vacated the district court’s dismissal of a plaintiff’s false imprisonment claim filed under 42 U.S.C. § 1983 against a Bartow County Sheriff’s deputy. The plaintiff claimed that he was falsely arrested and placed in custody for 21 days on a criminal trespass charge. The trial court dismissed the count against the deputy under the authority of Heck v. Humphrey, 512 U.S. 477, 114 S. Ct. 2364 (1994). In Heck, the U.S. Supreme Court held that “when a state prisoner seeks damages in a § 1983 suit, the district court must consider whether a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence.” 512 U.S. at 487, 114 S. Ct. at 2372. “[I]f it would, the complaint must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated.” Id. In this case, the plaintiff’s criminal trespass charge was dropped a month after his arrest when he pled guilty to wholly unrelated offenses. The district court agreed with the deputy that the plaintiff’s § 1983 claim was barred by Heck because the plaintiff could not show that the criminal trespass charge was terminated in his favor. The Eleventh Circuit concluded that the district court erred because the second stage of the analysis, requiring a showing by the plaintiff that the conviction or sentence had already been invalidated, is only triggered if a judgment for the plaintiff would invalidate the criminal conviction or sentence. Since the plaintiff’s criminal conviction and sentence was based on charges wholly unrelated to the trespass charge, the Eleventh Circuit concluded this could not be the case.