Edwards et al. v. Balisok
520 U.S. 641 (1997)
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Rule of Law:
A state prisoner's claim for damages or declaratory relief under 42 U.S.C. § 1983 is not cognizable if the claim challenges prison disciplinary procedures and a judgment in the prisoner's favor would necessarily imply the invalidity of the punishment imposed, unless that punishment has already been invalidated.
Facts:
- Jerry Balisok, an inmate at a Washington State Penitentiary, was charged with four prison infractions on August 16, 1993.
- At a disciplinary hearing on September 2, 1993, Balisok was found guilty of the infractions.
- As a result of the guilty finding, Balisok was sentenced to 10 days in isolation, 20 days in segregation, and the deprivation of 30 days of previously earned good-time credit.
- Balisok alleged that the hearing officer, Edwards, was deceitful and biased, intentionally concealed exculpatory witness statements, and refused to allow him to present evidence in his defense.
- Balisok's appeal within the prison's internal system was rejected for failure to comply with procedural requirements.
Procedural Posture:
- Jerry Balisok filed a 42 U.S.C. § 1983 action in the U.S. District Court against petitioner prison officials.
- The District Court held that a judgment in Balisok's favor would necessarily imply the invalidity of the disciplinary sanction and was therefore barred under Heck v. Humphrey.
- The District Court did not dismiss the action but stayed it pending resolution of a state-court action for restoration of the good-time credits, authorizing an immediate appeal of its ruling.
- The U.S. Court of Appeals for the Ninth Circuit, as the intermediate appellate court, reversed, holding that a claim challenging only the procedures of a disciplinary hearing is always cognizable under § 1983.
- The prison officials (petitioners) sought, and the U.S. Supreme Court granted, a writ of certiorari.
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Issue:
Does a state prisoner's claim for damages and declaratory relief under 42 U.S.C. § 1983, which challenges the validity of the procedures used to deprive him of good-time credits, constitute a cognizable claim if a judgment in his favor would necessarily imply the invalidity of the disciplinary sanction?
Opinions:
Majority - Justice Scalia
No. A state prisoner's claim for damages under § 1983 is not cognizable if its success would necessarily imply the invalidity of a disciplinary sanction affecting the duration of his sentence, unless that sanction has been favorably terminated. The Court extended the rule from Heck v. Humphrey, holding that even if a prisoner's claim is framed as a challenge to procedures rather than the substantive result, it is barred if the nature of the procedural challenge would necessarily invalidate the outcome. Balisok's claim alleged deceit and bias by the hearing officer, which is a structural defect akin to trial by a biased judge. If proven, such a defect would automatically invalidate the deprivation of good-time credits, regardless of the evidence. Therefore, his claims for damages and declaratory relief are not cognizable under § 1983 until he can show the disciplinary decision has been invalidated. However, a claim for prospective injunctive relief to prevent future violations may be cognizable and should be considered on remand.
Concurring - Justice Ginsburg
I agree that Balisok's claims based on allegations of deceit and bias are not cognizable under § 1983 because they necessarily imply the invalidity of the punishment. However, I write separately to emphasize that not all of Balisok's procedural claims would have this effect. For example, his claim that the hearing officer failed to provide a written statement of the evidence relied upon would not necessarily invalidate the outcome. Such a claim, which does not go to the core validity of the hearing, should be immediately cognizable under § 1983. I join the Court's opinion with this understanding.
Analysis:
This case clarifies and extends the favorable termination rule of Heck v. Humphrey to the context of prison disciplinary proceedings. It establishes that courts must look beyond the remedy sought by the prisoner and analyze the substance of the procedural challenge itself. By holding that a § 1983 claim is barred if it alleges a fundamental procedural defect (like a biased adjudicator) that would necessarily invalidate the outcome, the decision significantly narrows the ability of prisoners to use § 1983 to collaterally attack disciplinary sanctions that affect sentence duration. It forces prisoners with such claims to first seek relief through state court or federal habeas corpus, reinforcing the line between civil rights actions and challenges to the fact or duration of confinement.
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