Heck v. Humphrey

Summary

The Supreme Court held that a state prisoner may not recover damages under 42 U.S.C. § 1983 for an allegedly unconstitutional conviction, imprisonment, or related conduct when success would necessarily imply the invalidity of the conviction or sentence, unless that conviction or sentence has already been invalidated. The Court distinguished claims that would not necessarily demonstrate the invalidity of an outstanding criminal judgment, which may proceed absent another bar. The judgment affirming dismissal of the plaintiff's damages action was affirmed.

Holdings

1. A § 1983 plaintiff may not recover damages for an allegedly unconstitutional conviction or imprisonment, or for other harm caused by conduct whose unlawfulness would render the conviction or sentence invalid, unless the conviction or sentence has already been reversed on direct appeal, expunged by executive order, declared invalid by an authorized state tribunal, or called into question by a federal court's issuance of a writ of habeas corpus.
2. A district court must determine whether judgment in the plaintiff's favor would necessarily imply the invalidity of an outstanding criminal judgment. If so, the complaint must be dismissed unless the conviction or sentence has already been invalidated; if not, the action may proceed absent another bar.
3. A § 1983 cause of action for damages attributable to an unconstitutional conviction or sentence does not accrue until the conviction or sentence has been invalidated.

Questions Presented

1. Whether a state prisoner may seek damages under 42 U.S.C. § 1983 for alleged constitutional violations when success would necessarily imply that the prisoner's conviction or sentence is invalid.
2. Whether such a § 1983 damages claim is barred because the conviction or sentence has not previously been reversed, expunged, invalidated, or called into question through federal habeas corpus.
3. Whether the bar is an exhaustion requirement or instead a limitation on the cognizability and accrual of the § 1983 cause of action.

Disposition

affirmed