Because a public defender performing traditional functions as counsel in a criminal proceeding—as Defendant Craig is alleged to have done here—does not act under color of state law within the meaning of 42 U.S.C. § 1983, Plaintiff fails to state a claim against Craig. Polk County v. Dodson, 454 U.S. 312, 325 (1981) ("a public defender does not act under color of state law when performing a lawyer's traditional functions as counsel to a defendant in a criminal proceeding"); Rogers v. Bruntrager, 841 F.2d 853, 856 (8th Cir. 1988) (same); see also Williams v. Butler, No. 4:19-CV-04126, 2020 WL 1281663, at *2 (W.D. Ark. Feb. 26, 2020), report and recommendation adopted, No. 4:19-CV-4126, 2020 WL 1281243 (W.D. Ark. Mar. 17, 2020) (claim that public defender failed to adequately represent client in criminal proceedings does not state cognizable § 1983 claim); Moment v. Iowa, No. C19-1029, 2019 WL 6529133, at *3 (N.D. Iowa Dec. 4, 2019) (state public defender was immune from § 1983 suit when plaintiff claimed ineffective assistance of counsel for failing to object to speedy trial issue); Fleming v. Circuit Court of St. Louis, No. 4:10-CV-2274, 2011 WL 43015, at *2 (E.D. Mo. Jan. 6, 2011) (plaintiff's § 1983 claim of ineffective assistance of counsel against public defender was legally frivolous because public defenders performing lawyers' traditional functions do not act under color of state law for purposes of § 1983).