Preiser v. Rodriguez - 411 U.S. 475, 93 S. Ct. 1827 (1973)

Rule:

Congress determines that habeas corpus is the appropriate remedy for state prisoners attacking the validity of the fact or length of their confinement, and that specific determination must override the general terms of 42 U.S.C.S. § 1983.

Facts:

Three New York State prisoners brought separate suits under 42 USCS 1983 in the United States District Court for the Northern District of New York, challenging the constitutionality of disciplinary action by the New York State Department of Correctional Services in depriving them of good conduct time credits. In each case, the District Court held that the disciplinary action was unconstitutional and that the prisoners were not required to exhaust their state remedies before suing under 42 USCS 1983; and since their conditional release dates had already passed, the court's order to restore their good conduct time credits entitled them to immediate release. The United States Court of Appeals for the Second Circuit affirmed. The New York State Department of Corrections challenged the decision, contending that the state prisoners were only entitled to bring their complaints as federal habeas corpus petitions; therefore, the complaints should have been dismissed for failure to exhaust administrative remedies.

Issue:

Under the circumstances, were the state prisoners only entitled to bring their complaints as federal habeas corpus petitions?

Answer:

Yes.

Conclusion:

The United States Supreme Court reversed the appellate court's decision. When a state prisoner was challenging the very fact or duration of his physical imprisonment, and the relief he sought was a determination that he was entitled to immediate release or a speedier release from that imprisonment, his sole federal remedy was a writ of habeas corpus. The state prisoners were therefore not able to proceed under § 1983.