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Roy C. Lewellen, Jr. v. Gene Raff, Individually and in His Official Capacity as Prosecuting Attorney for the First Judicial District of Arkansas David Cahoon, Individually and in His Official Capacity as Deputy Prosecuting Attorney for Lee County, Arkansas Henry Wilkinson, Individually and in His Official Capacity as Circuit Court Judge for the First Judicial District of Arkansas, Lafayette Patterson Jeanne Kennedy Doug Williams Lee County, Arkansas Robert May, Jr., Individually and in His Official Capacity as Sheriff of Lee County. Lafayette Patterson v. Robert Banks Margie Banks Reverend Almore Banks (Four Cases). Roy C. Lewellen, Jr. v. Gene Raff, Individually and in His Official Capacity as Prosecuting Attorney for the First Judicial District of Arkansas David Cahoon, Individually and in His Official Capacity as Deputy Prosecuting Attorney for Lee County, Arkansas Lafayette Patterson Jeanne Kennedy Doug Williams, Lee County, Arkansas Robert May, Jr., Individually and in His Official Capacity as Sheriff of

Citation: 843 F.2d 1103Docket: 87-1069

Court: Court of Appeals for the First Circuit; April 4, 1988; Federal Appellate Court

Narrative Opinion Summary

This case involves multiple appeals stemming from a federal lawsuit filed by Lewellen, a defense attorney, against various state officials, including prosecutors and law enforcement officers, in connection with a state criminal prosecution. The core legal issue centers around whether the federal district court should have abstained from intervening in the state prosecution under the Younger abstention doctrine. The district court found that the prosecution was initiated in bad faith to retaliate against Lewellen for exercising his constitutional rights, thus justifying federal intervention. The court issued a preliminary injunction preventing the state trial from proceeding, which was upheld upon appeal. Prosecutors were granted absolute immunity regarding defamation claims, while law enforcement officers were granted qualified immunity on claims of unlawful investigation and prosecution. The court dismissed Lewellen's claims under sections 1983 and 1985, citing a lack of evidence for racial discrimination or conspiracy. The outcome favored the defendants, affirming the absolute and qualified immunities and dismissing most claims against the state officials, while maintaining the injunction against the state prosecution.

Legal Issues Addressed

Absolute Immunity of Prosecutors

Application: Prosecutors Raff and Cahoon were granted absolute immunity against defamation claims as their actions were within the scope of judicial proceedings.

Reasoning: In a separate matter, the district court granted absolute immunity to prosecutors Raff and Cahoon regarding Lewellen's defamation claim, as the information they disclosed stemmed from judicial proceedings.

Qualified Immunity for Law Enforcement

Application: Officers involved in the investigation were granted qualified immunity as their actions did not violate clearly established law.

Reasoning: Sgt. Williams and Sheriff May sought dismissal or summary judgment based on qualified immunity, which the district court largely denied, stating they might have violated clearly established rights.

Retaliatory Prosecution

Application: The district court determined that the criminal prosecution against Lewellen was initiated in bad faith, aiming to retaliate for his exercise of federally protected rights.

Reasoning: The district court determined that the criminal prosecution against Lewellen was initiated in bad faith, aiming to retaliate for his exercise of federally protected rights.

Section 1983 and 1985 Claims

Application: Lewellen's claims under sections 1983 and 1985 were dismissed due to insufficient evidence to support allegations of conspiracy and racial discrimination.

Reasoning: Count Two of Lewellen's complaint asserted that Williams and May conspired to entrap him with baseless criminal charges and subsequently covered up this conspiracy, aiming to deny him equal protection based on race, in violation of 42 U.S.C. Secs. 1983 and 1985.

Younger Abstention Doctrine

Application: The court evaluated whether federal intervention in a state criminal prosecution was justified, deciding not to abstain under the Younger doctrine due to bad faith prosecution.

Reasoning: The central issue is whether the federal district court properly declined to apply Younger abstention, which would have prevented federal intervention in a state criminal prosecution of Reverend Almore Banks, a black minister accused of rape.