Fetters v. County of Los Angeles
243 Cal.App.4th 825, 196 Cal. Rptr. 3d 848, 2016 Cal. App. LEXIS 11 (2016)
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Rule of Law:
A plaintiff's prior criminal proceeding that is resolved by admitting the charges in exchange for informal probation, which is followed by a dismissal upon successful completion, does not constitute a 'favorable termination' of the criminal case. Therefore, a subsequent § 1983 claim for excessive force arising from the same incident is barred by the doctrine established in Heck v. Humphrey.
Facts:
- On May 10, 2009, 15-year-old William Fetters was playing 'cops and robbers' with friends while carrying a replica semiautomatic pistol.
- Two Los Angeles County Sheriff's deputies, Stephen Sorrow and Andrew Campbell, spotted Fetters riding his bicycle alone with the replica gun.
- The deputies made a U-turn in their patrol car and approached Fetters from behind.
- After the deputies ordered Fetters to stop, he complied by stopping his bicycle.
- Immediately following the stop, a disputed sequence of events occurred, culminating in Deputy Sorrow firing a single shot that wounded Fetters in the chest.
- The entire encounter, from the time the deputies began issuing commands until the shot was fired, lasted approximately seven seconds or less.
Procedural Posture:
- William Fetters was charged in Los Angeles County juvenile court with three misdemeanor counts of brandishing an imitation firearm.
- Pursuant to a plea bargain, Fetters admitted the charges and was placed on six months' informal probation.
- After Fetters successfully completed probation, the juvenile court granted his motion to withdraw his plea and dismissed the petition against him.
- Fetters filed a civil suit in state trial court against the deputies and the County of Los Angeles, alleging a violation of his civil rights under 42 U.S.C. § 1983.
- The trial court held a separate bench trial on the defendants' Heck v. Humphrey defense and ruled in favor of Fetters, finding his claim was not barred.
- A jury trial was subsequently held on the § 1983 claim, resulting in a partial verdict for Fetters for approximately $1.1 million in compensatory damages.
- The County of Los Angeles (appellant) appealed the judgment and a subsequent attorney fees award to the California Court of Appeal.
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Issue:
Does a juvenile's admission to brandishing an imitation firearm, followed by the successful completion of informal probation and subsequent dismissal of the charges, constitute a 'favorable termination' sufficient to permit a § 1983 claim for excessive force arising out of the same incident?
Opinions:
Majority - Johnson, J.
No. A § 1983 claim is barred under Heck v. Humphrey if it necessarily implies the invalidity of a prior criminal conviction or sentence that has not been favorably terminated. Here, Fetters's admission to the brandishing charges, even though resolved with informal probation and eventual dismissal, serves as a conviction for Heck purposes and was not terminated in a manner reflecting his innocence. The court applied a three-part analysis. First, it found that Fetters's admission in the juvenile proceeding constituted a conviction, and the six months of informal probation constituted a sentence. Second, a judgment for Fetters on his excessive force claim would necessarily imply the invalidity of that conviction, as it would contradict his admission that he brandished the weapon in a manner that caused Deputy Sorrow reasonable fear of bodily harm, especially given that the events were part of a single, continuous, and brief incident. Third, the court held that the dismissal of the charges was not a 'favorable termination' because it resulted from a plea bargain and successful probation, not from an acquittal or any indication of Fetters's innocence. This type of resolution leaves a 'residue of doubt' about innocence and is therefore not favorable for the purpose of overcoming the Heck bar.
Analysis:
This decision solidifies the application of the Heck v. Humphrey bar in California, particularly for civil rights claims following criminal resolutions short of a full trial and acquittal. It establishes that dismissals resulting from diversion programs or informal probation are not 'favorable terminations' because they do not reflect the accused's innocence. This ruling narrows the ability of civil plaintiffs to challenge the conduct of law enforcement when they have previously accepted a plea bargain to resolve the underlying criminal charges, thereby reinforcing judicial policy against collateral attacks on criminal judgments.
