Dimitri S. Wolf, a/k/a Iokepa Kenneth Kipi v. Cookie Crews, et al.

Summary

The United States District Court for the Eastern District of Kentucky dismissed without prejudice a pro se prisoner’s 42 U.S.C. § 1983 complaint challenging the procedures and evidentiary sufficiency of a prison disciplinary conviction. Because the requested relief included restoration of good-conduct credits and other relief that would undermine or alter the disciplinary conviction and sentence, the court held that the claims were not cognizable in a civil-rights action. The matter was stricken from the docket.

Holdings

1. A prisoner cannot use § 1983 to pursue a constitutional claim challenging the procedures or evidentiary basis of an extant disciplinary conviction when success would imply that the conviction or resulting punishment is invalid.
2. A prisoner may not obtain earlier release from custody through a § 1983 civil-rights proceeding.

Questions Presented

1. Whether a prisoner may use 42 U.S.C. § 1983 to obtain damages or other relief by challenging the procedures and evidentiary sufficiency underlying an extant prison disciplinary conviction that resulted in the loss of good-conduct credits.
2. Whether a prisoner may obtain earlier release from custody through a § 1983 civil-rights action.

Disposition

dismissed