Protection Against Malpractice Suits In Civil Rights Cases Upheld

Armstrong Teasdale LLP

Armstrong Teasdale LLP

On April 27, 2023, the United States District Court for the Central District of Illinois dismissed Aaron Edwards’ (“Plaintiff”) complaint for failure to state a claim. The case was filed against Sangamon County Jail, an unknown Sangamon County Judge, Public Defender William Vig, the Governor of Illinois, and former President Donald Trump. Edwards v. Sangamon Co. Detention Facility, et al., No. 22-3209, 2023 WL 3137969 at *1 (C.D. Ill. Apr. 27, 2023).

Plaintiff initially filed suit in the Southern District of Mississippi, but the case was transferred to the Central District of Illinois. Id. Plaintiff then filed an amended complaint, that was dismissed. Plaintiff then filed a motion for leave to file a second amended complaint, and the Court entered a “Merit Review Order” to “screen” the second amended complaint and identify and dismiss any legally insufficient claims. Id. Plaintiff’s second amended complaint alleged that, from Jan. 3, 1991, to Nov. 3, 2022, the Sangamon County Jail violated his civil rights by “not letting me have a fair trial,” “beatings,” and making him sleep on the floor. Id. Plaintiff’s second amended complaint also alleged that his public defender was not prompt, and that the public defender’s representation prior to Plaintiff’s conviction was deficient. Id.

After screening Plaintiff’s second amended complaint, the Court found numerous defects. Id., at *2-3. The first and most evident problem with Plaintiff’s amended complaint was that it brought unrelated claims against different defendants in one suit. Id. at *1. Second, Plaintiff’s civil rights claims were time-barred. Id. at *2. Third, many of the named defendants were immune from suit. Id.

Regarding the legal malpractice claim, the Court stated, “the law is clear that a party may not sue his attorney for legal malpractice in a civil rights suit, and this principle holds true even if that attorney was court-appointed and employed by the state.” Id. (internal citations omitted). Simply stated, legal services provided to protect the rights privileges, or immunities secured by the Constitution will not expose a lawyer to liability for legal malpractice.

The Court gave short and concise retorts to the remaining claims and dismissed Plaintiff’s complaint in its entirety. Id.

Edwards v. Sangamon Co. Detention Facility, et al., 2023 WL 3137969

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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