Derrick Dewayne Parker, filing the lawsuit as a pretrial detainee, sued a long list of judges, prosecutors, law enforcement officers, and attorneys involved in his state criminal cases. He alleged that these defendants violated his Fourth and Sixth Amendment rights by providing false information for search warrants, failing to issue proper warrants, preventing him from confronting accusers, and denying him a speedy trial. Parker was involved in two Oklahoma cases: one where charges were dismissed and another where he pled guilty to trafficking fentanyl. The district court dismissed the entire action, ruling that claims challenging his guilty plea were barred by the Supreme Court's decision in Heck v. Humphrey, that the judges and prosecutors were immune from suit, and that the remaining allegations failed to state a valid claim.
The Tenth Circuit reviewed the dismissal de novo, applying a liberal construction to Parker's pro se filings but refusing to advocate on his behalf. The court first addressed the application of Heck v. Humphrey, which bars civil rights claims for damages if the actions complained of would render an existing criminal conviction invalid. The court rejected Parker's argument that Heck did not apply because he was a pretrial detainee, noting that his conviction for trafficking fentanyl had not been overturned and that existing case law applies Heck to pretrial detainees whose claims would take aim at the heart of their criminal plea. The court also declined to consider Parker's new argument that prosecutors violated Brady v. Maryland by failing to disclose exculpatory evidence, as this theory was not raised in the district court. Finally, the court affirmed the lower court's ruling on absolute judicial and prosecutorial immunity, which shields these officials from liability for acts performed within their official capacities.
Parker's civil suit is dismissed without the court reaching the merits of his Fourth and Sixth Amendment assertions. The decision reinforces that individuals cannot use § 1983 lawsuits to indirectly challenge a criminal conviction that remains valid. It also clarifies that judges and prosecutors retain absolute immunity for their official acts, and litigants must raise all constitutional theories in the district court to preserve them for appeal.
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