# Brown v. Caird

> District Court, S.D. Texas · March 18, 2022

URL: https://www.frixlaw.com/law-library/cases/10675234

## Case

- **Court:** District Court, S.D. Texas
- **Decided:** March 18, 2022
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

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## Opinion text

, United States District Cov
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF THRAS St of □□
ENTERED
AAT 18, 2022
Nathan Ochsner, Clerk
Casey Ray Brown, et al., §
Plaintiffs, ;
versus § Civil Action H-22-0784
Jessica Alane Caird, :
Defendant. ;
Opinion on Final Dismissal
Casey Ray Brown and DeAndre Dynell DeBoest are prisoners in the
Harris County Jail. Brown and DeBoest are both in custody under several
pending felony charges. The plaintiffs filed a civil rights action under 42
U.S.C. § 1983, alleging that Jessica Alane Caird, a Chief Assistant District
Attorney, violated their speedy trial rights. They both say they wish to
represent themselves because their court-appointed attorney will not
protect their speedy trial rights. They seek monetary relief and injunctive
relief in the form of having their criminal cases dismissed.
Success on an alleged speedy trial or self-representation violation
necessarily implies the unlawfulness of a criminal conviction or detention.
Claims such as these are strictly habeas in nature, and a prisoner must bring
them in a petition for a writ of habeas corpus. Brown and DeBoest cannot
bring these claims in a civil rights action until they show that their
convictions have been overturned or otherwise invalidated because of the
Supreme Court’s ruling in Heck v. Humphrey, 512 U.S. 477 (1994). Brown
and DeBoest may not seek monetary or injunctive relief in a civil rights
action until they make this showing. Accordingly, Brown and DeBoest must
bring these claims in a habeas corpus petition rather than this civil rights
action because they have not shown their convictions have been overturned
or otherwise invalidated.
The court will not construe this civil rights complaint into a habeas’)
action for the defendants because the Supreme Court’s decision in Younger

v. Harris, 401 U.S. 37 (1971), limits their request that the court enjoins their
state criminal prosecutions. Younger abstention applies when: (a) the
claims involve an ongoing state judicial proceeding; (b) the State has an
important interest in the state judicial proceeding; and (c) the state judicial
proceeding affords an adequate opportunity to raise constitutional
challenges. Abstaining from intervention is particularly appropriate when a
plaintiff can enforce his constitutional rights in his defense to criminal
prosecution. Both plaintiffs fail to show that the court should not apply
Younger to this case because they make only conclusory statements that the
state trial proceedings are not protecting their rights. Moreover, assuming
they are convicted on the charges, both plaintiffs may enforce their rights as
a defense to prosecution through direct appeal.
Even if they could presently bring these claims in a civil rights action,
prosecutors are absolutely immune from monetary damages for any claim
about initiating a prosecution, presenting the State’s case, or an action
intimately associated with the judicial phase of a criminal prosecution.
Immunity is waived only if the prosecutor acts in the clear absence of
authority. Brown and DeBoest’s claims are intimately associated with
Caird’s role as a prosecutor during the judicial phase of prosecution because
they involve actions taken during the prosecution of their charges.
Therefore, the claims for monetary damages should be dismissed because
Caird enjoys absolute immunity. While prosecutors do not enjoy immunity
for injunctive relief, the relief sought is barred by Heck, because granting the
relief would imply the invalidity of their prosecution, and Younger, because
granting relief would force the court to enjoin their criminal proceedings.
The civil rights complaint will be dismissed with prejudice for failing
to state a claim for relief.

Signed at Houston, Texas, on MM anche Le , 2022. □

Lynn N. Hughes
United States District Judge

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10675234. Public record. Not legal advice.