Roger L. Compton, Jr. v. L.S. Crews, et al.

Summary

The United States District Court for the Western District of Virginia dismissed Roger L. Compton Jr.'s pro se 42 U.S.C. § 1983 action following screening under 28 U.S.C. § 1915A. The court held that requests for release must be pursued through habeas corpus rather than § 1983 and that damages claims barred by Heck v. Humphrey could not proceed absent invalidation of the underlying conviction or sentence.

Holdings

1. A § 1983 civil rights action is not the proper vehicle for challenging the legality of confinement or seeking release; such relief must be pursued through habeas corpus.
2. Under Heck v. Humphrey, a plaintiff cannot obtain damages through § 1983 when success would imply the invalidity of a conviction or sentence unless the conviction or sentence has already been invalidated.
3. The complaint failed to state a claim upon which relief could be granted and was subject to dismissal under 28 U.S.C. § 1915A.

Questions Presented

1. Whether Compton could use a 42 U.S.C. § 1983 action to obtain release from allegedly unlawful confinement.
2. Whether Compton could recover damages arising from his allegedly wrongful conviction or confinement before showing that the conviction or sentence had been invalidated.
3. Whether the complaint stated a claim cognizable in federal district court under the applicable prisoner-screening standards.

Disposition

dismissed