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HAMPTON v. TUNICA COUNTY MISSISSIPPI (2021)

United States Court of Appeals, Fifth Circuit.2021-08-24No. No. 20-60232

Summary

Holding. The appeal was dismissed as frivolous. Hampton was assessed a strike under the three-strikes rule for in forma pauperis proceedings and warned that accumulation of three strikes would bar him from proceeding in forma pauperis while incarcerated, and that further frivolous or repetitive filings would result in sanctions.

Willie Hampton, a federal prisoner serving a life sentence for drug-trafficking convictions imposed in 2001, filed a civil rights action under 42 U.S.C. § 1983 challenging his arrest, conviction, and various forfeitures of property. The district court dismissed the action as untimely and barred by issue and claim preclusion, since all matters Hampton raised had been conclusively decided against him in prior proceedings, including his criminal trial, a federal habeas petition, a previous civil rights action, and a federal forfeiture action. Additionally, Hampton's allegations were too vague and conclusional to state a constitutional violation, and his speedy-trial claim was moot because he had already prevailed on that issue in state court litigation that resulted in return of his cars and cash in 2018.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether prior litigation barred the civil rights action through issue and claim preclusion
  • Whether Hampton's allegations stated a constitutional violation with sufficient specificity
  • Whether Hampton's speedy-trial claim was moot due to success in state court

Procedural posture

Hampton appealed the district court's dismissal of his § 1983 civil rights action filed in forma pauperis, raising claims about a conspiracy related to his conviction and the forfeiture of property.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Willie Hampton, federal prisoner # 79948-011, is serving a life sentence imposed in 2001 after a jury convicted him of drug-trafficking offenses. Proceeding in forma pauperis (IFP), he appeals the dismissal of his action brought under 42 U.S.C. § 1983. Hampton alleged a conspiracy that resulted in his arrest and conviction, as well as a state law forfeiture of cars and cash and a federal forfeiture of real property. Years of state court litigation resulted in the return, in 2018, of his cars and cash based on a violation of his speedy-trial rights. We dismissed an appeal of the federal forfeiture in 2003.

The district court dismissed the action as untimely and as barred by collateral estoppel, or issue preclusion. All of the issues Hampton raises in his complaint and brief were conclusively decided against him in his criminal proceeding, his first proceeding under 28 U.S.C. § 2255, a 2006 federal civil rights action, or the federal forfeiture action. Under the doctrines of issue preclusion and claim preclusion, these issues may not be relitigated against these defendants. See United States v. Shanbaum, 10 F.3d 305, 310-11 (5th Cir. 1994); United States v. Mollier, 853 F.2d 1169, 1175 n.7 (5th Cir. 1988); Lubrizol Corp. v. Exxon Corp., 871 F.2d 1279, 1288-89 (5th Cir. 1989); see also Heck v. Humphrey, 512 U.S. 477, 486-87, 114 S.Ct. 2364, 129 L.Ed.2d 383 (1994).

In any event, his assertions are too vague and conclusional to state any constitutional violation. See Morrison v. City of Baton Rouge, 761 F.2d 242, 244 (5th Cir. 1985). To the extent Hampton contends he is entitled to a hearing on the speedy-trial factors of Barker v. Wingo, 407 U.S. 514, 530-35, 92 S.Ct. 2182, 33 L.Ed.2d 101 (1972), his claim is moot because he prevailed on that issue in state court. See Los Angeles Cnty. v. Davis, 440 U.S. 625, 631, 99 S.Ct. 1379, 59 L.Ed.2d 642 (1979).

In light of the foregoing, we dismiss the appeal as frivolous. See 5th Cir. R. 42.2. We need not examine whether, under Mississippi law, Hamptons state litigation tolled the limitations period in which he could raise claims based on the state forfeiture.

The dismissal of this appeal as frivolous counts as a strike under 28 U.S.C. § 1915(g). See Coleman v. Tollefson, 575 U.S. 532, 537, 135 S.Ct. 1759, 191 L.Ed.2d 803 (2015). Hampton is warned that, if he accumulates a total of three strikes, he will be barred from proceeding IFP in any civil action or appeal filed while he is incarcerated or detained in any facility unless he is under imminent danger of serious physical injury. See § 1915(g). Hampton is further warned that the filing of further frivolous or repetitive actions or appeals challenging his convictions, sentences, or forfeitures, even if he is not proceeding IFP, will result in sanctions, including monetary sanctions and limits on his access to this court and any court subject to this courts jurisdiction.

APPEAL DISMISSED AS FRIVOLOUS; STRIKE IMPOSED; SANCTION WARNING ISSUED.

FOOTNOTES

FOOTNOTE

Per Curiam:*

FN* Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4.