Background
Thomas Tarbutton appealed pro se from a district court judgment that denied him in forma pauperis status and dismissed his action. The action alleged various violations of the Constitution, federal laws, and state statutes by individuals involved in his arrest and state criminal proceedings.
The court’s reasoning
The panel reviewed the denial of in forma pauperis status for an abuse of discretion. The court concluded that Tarbutton’s action is barred by Heck v. Humphrey. This precedent bars claims that a judicial decisionmaker is biased, claims based on lack of probable cause for arrest and imprisonment, and ineffective assistance of counsel claims.
What it means going forward
The decision prevents civil rights challenges to criminal proceedings that would imply the invalidity of a conviction or sentence unless those proceedings have been reversed or expunged.
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