Unreported / Non-Citable
Background
Jason Wilson sued Alameda County and Deputy District Attorneys Michiye Vella and Laura Anderson over their conduct in his state criminal prosecution. He alleged that the prosecutors failed to correct testimony contradicted by written communications and failed to disclose those communications to the defense, and he challenged protective-order applications filed after he sued prosecution witnesses. His complaint asserted Napue and Brady claims, a First Amendment retaliation claim, Monell and equal-protection claims against the County, a state-law civil conspiracy claim, and a due-process challenge to California Evidence Code sections 1108 and 1109.
Wilson was arrested in June 2023 and pleaded no contest on June 22, 2026, to felony domestic violence under Penal Code section 273.5, admitting an enhancement; he was sentenced on July 21, 2026, to three years of formal probation. He filed this suit on June 2, 2026. The County moved to dismiss on June 26, 2026, arguing failure to state a claim and the Heck bar, and the DDA Defendants moved on August 31, 2026, asserting prosecutorial immunity. The court took judicial notice of the state criminal and related civil records, heard oral argument on October 7, 2026, accepted the complaint's factual allegations as true under Rule 12(b)(6), and construed his pro se filing liberally.
The Court’s Holding
The court granted the County's motion to dismiss in full, dismissing all six causes of action against the County. It dismissed the first, second, third, fourth, and sixth causes of action without leave to amend and without prejudice because they were barred by Heck v. Humphrey: success on the false-testimony (Napue) and nondisclosure (Brady) claims would necessarily imply the invalidity of Wilson's conviction, including because the challenged evidence concerned the credibility of the witness whose testimony supported that conviction. A no-contest plea does not avoid Heck, and claims focused on a dismissed charge remain barred when the evidence also bears on the offense of conviction. The derivative Monell claim failed under Heck and for lack of facts establishing a County policy, custom, or failure to train. The equal-protection claim was Heck-barred as selective enforcement and also failed because Wilson did not allege differential treatment of similarly situated defendants or discriminatory intent. The civil conspiracy claim was Heck-barred and inadequately pleaded because state-law civil conspiracy is not an independent cause of action and Wilson alleged no underlying tort.
The fifth cause of action, alleging First Amendment retaliation through DDA Vella's protective-order applications, was not barred by Heck because the applications were denied, and Younger abstention did not apply because probation is not a pending criminal action. Nevertheless, the court found that Wilson failed to allege a County policy or a plausible but-for causal connection between retaliatory motive and injury; mere awareness of his protected activity and timing were insufficient. That claim was dismissed with leave to amend within 20 days.
The court granted the DDA Defendants' motion with leave to amend within 20 days, holding that the challenged conduct — failing to disclose impeachment material, failing to correct testimony, and filing protective-order applications — fell within their role as advocates for the State and was shielded by absolute prosecutorial immunity under Imbler v. Pachtman. The court also rejected Wilson's due-process challenge to Evidence Code sections 1108 and 1109 as settled law and held that his requests for injunctive and declaratory relief were moot or otherwise unavailable.
Key Takeaways
- A no-contest plea does not prevent Heck from barring damages claims whose success would necessarily invalidate the resulting conviction.
- Claims focused on a dismissed charge may still be Heck-barred when the challenged evidence also affects the offense of conviction.
- Allegations about prosecutors' conduct in a single criminal case did not adequately establish an Alameda County policy, custom, or failure to train for Monell liability.
- Denied protective-order applications avoided Heck and Younger barriers, but timing and awareness alone did not plausibly establish retaliatory causation.
- Absolute prosecutorial immunity covered the challenged advocacy functions, though Wilson received 20 days to attempt to plead complaining-witness conduct outside that protection.
Why It Matters
The decision separates procedural barriers from the merits of Wilson's allegations. The Heck-barred claims were dismissed without prejudice, and the order expressly states that Wilson may seek relief if his conviction is overturned on appeal or through a habeas petition. The retaliation claim and the claims against the prosecutors instead received limited 20-day opportunities to amend.
The ruling illustrates the distinct inquiries governing municipal liability, prosecutorial immunity, abstention, and retaliation in a single order. Wilson's requested pretrial disclosure injunction was moot after his plea, and declaratory relief was unavailable because he alleged completed injuries rather than possible future violations.