Heck v. Humphrey
512 U.S. 477 (1994)
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Rule of Law:
A claim for damages under 42 U.S.C. § 1983 is not cognizable if a judgment in the plaintiff's favor would necessarily imply the invalidity of their criminal conviction or sentence, unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated.
Facts:
- Roy Heck was convicted in an Indiana state court of voluntary manslaughter for the killing of his wife, Rickie Heck.
- Heck was sentenced to serve 15 years in prison.
- While his conviction was on appeal, Heck filed a lawsuit against county prosecutors James Humphrey and Robert Ewbank, and state police investigator Michael Krinoph.
- Heck alleged that the defendants engaged in an unlawful investigation, knowingly destroyed exculpatory evidence, and used an illegal voice identification procedure at his trial.
- Heck claimed these actions resulted in his unconstitutional arrest and conviction.
- In his lawsuit, Heck sought compensatory and punitive monetary damages, but did not seek release from custody.
Procedural Posture:
- Roy Heck filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court.
- The District Court dismissed Heck's action without prejudice.
- Heck, as the appellant, appealed the dismissal to the U.S. Court of Appeals for the Seventh Circuit.
- The Seventh Circuit affirmed the District Court's judgment.
- The U.S. Supreme Court granted Heck's petition for a writ of certiorari to review the Seventh Circuit's decision.
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Issue:
Is a claim for damages under 42 U.S.C. § 1983 cognizable if a judgment in the plaintiff's favor would necessarily render his outstanding criminal conviction or sentence invalid?
Opinions:
Majority - Justice Scalia
No. A state prisoner's claim for damages under § 1983 is not cognizable if a judgment in his favor would necessarily imply the invalidity of his conviction or sentence. Drawing an analogy to the common-law tort of malicious prosecution, which requires that the prior criminal proceeding terminate in the accused's favor, the Court reasoned that civil tort actions are not the proper vehicle for challenging the validity of outstanding criminal judgments. This 'favorable termination' requirement avoids parallel litigation and prevents a plaintiff from succeeding in a tort action after being convicted, which would create conflicting resolutions. Therefore, to bring a § 1983 claim for an allegedly unconstitutional conviction, the plaintiff must first prove the conviction or sentence has been reversed, expunged, declared invalid by a state tribunal, or called into question by a federal court's grant of a writ of habeas corpus. This is not an exhaustion requirement, but a fundamental element of the cause of action itself, meaning the claim does not accrue until the conviction is invalidated.
Concurring - Justice Thomas
Yes, concurring in the judgment. The conflict between § 1983 and the federal habeas corpus statute was created by the Court's own expansion of both statutes beyond their original scopes. Because the Court created this tension, it is proper for the Court to devise a principled limitation to resolve it. The majority's holding is a principled solution because it is consistent with the federalism concerns underlying the habeas statute's exhaustion requirement and with the common law of torts as it existed when § 1983 was enacted.
Concurring - Justice Souter
No, concurring in the judgment. While the result is correct, the majority's reliance on the malicious prosecution analogy is misplaced. A better approach is to harmonize the general § 1983 statute with the specific habeas corpus statute, as was done in Preiser v. Rodriguez. The habeas statute's exhaustion requirement embodies a congressional policy that state courts get the first opportunity to review claims challenging a prisoner's confinement. Allowing a § 1983 damages claim that implicitly attacks the conviction would frustrate this policy. Therefore, the statutory scheme requires a prisoner to first invalidate their conviction, as on appeal or through habeas corpus, before seeking damages under § 1983. This analysis avoids the majority's potentially problematic application of its rule to individuals who are not in custody and thus cannot seek habeas relief.
Analysis:
This case establishes the 'Heck bar,' a significant procedural hurdle for state prisoners filing § 1983 lawsuits. By mandating that a conviction be invalidated as a prerequisite for a damages claim challenging that conviction, the Court effectively channels such challenges through the habeas corpus system first. This promotes principles of comity and finality by preventing federal civil courts from acting as appellate reviewers of state criminal convictions. The decision clarifies the relationship between § 1983 and habeas corpus, solidifying habeas as the primary federal vehicle for inmates to challenge the lawfulness of their confinement.
