Parker v. Lyons

Dist. Ct. did not err in dismissing plaintiff’s lawsuit, alleging that defendant-State’s Attorney’s enforcement of state statute that precluded plaintiff from running as candidate for local school board seat due to his prior felony theft conviction essentially violated due process and equal protection clauses because defendant had targeted him on account of his African-American race. Plaintiff’s lawsuit against defendant in his official capacity was barred by 11th Amendment, and defendant was entitled to absolute prosecutorial immunity with respect to any claim against defendant in his individual capacity. Moreover, underlying state statute prohibiting plaintiff from holding public office due to his felony conviction did not violate equal protection clause, even though plaintiff claimed that statute had disparate impact on African-American men, since plaintiff needed to allege that legislature acted with discriminatory purpose when enacting statute.