Heck v. Humphrey

512 U.S. 477, 114 S. Ct. 2364 (1994)

 

RULE:

A claim for damages bearing that relationship to a conviction or sentence that has not been so invalidated is not cognizable under 42 U.S.C.S. § 1983. Therefore,  42 U.S.C.S. § 1983 damages plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court's issuance of a writ of habeas corpus, 28 U.S.C.S. § 2254

FACTS:

A prisoner who had been convicted in Indiana state court of voluntary manslaughter filed an action under 42 USCS 1983 in United States District Court, alleging that two prosecutors and a state investigator had engaged in an "unlawful, unreasonable, and arbitrary investigation" leading to his arrest, had knowingly destroyed exculpatory evidence, and had caused "an illegal and unlawful voice identification procedure" to be used at his trial. He sought, among other things, compensatory and punitive damages, but did not seek injunctive relief or release from custody. The District Court dismissed the action without prejudice. While his appeal to the United States Court of Appeals for the Seventh Circuit was pending, the Indiana Supreme Court upheld his conviction and sentence on direct appeal, and his petitions for federal habeas corpus relief were dismissed or denied. The Court of Appeals affirmed the dismissal of the prisoner's 1983 action, stating that where a prisoner in such an action challenges the legality of his conviction--so that if he were to win his case, the state would be obliged to release him even if he had not sought such relief--the action is classified as one for habeas corpus and as such is subject to the requirement of exhaustion of state remedies 

ISSUE:

In light of the prisoner’s allegation that the prosecutors and the state investigator engaged in an unlawful, unreasonable, and arbitrary investigation which led to his arrest, was the prisoner entitled to compensatory and punitive damages?

ANSWER:

No.

CONCLUSION:

The Supreme Court held that in order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a plaintiff in a 42 U.S.C.S. § 1983 action was required to prove that the conviction or sentence had been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such a determination, or called into question by a federal court's issuance of a writ of habeas corpus under 28 U.S.C.S. § 2254. The inmate's claim was not cognizable under 42 U.S.C.S. § 1983. The Court noted that both lower federal courts found inmate's damages claims challenged the legality of his conviction; therefore, the action was correctly dismissed.

Click here to view the full text case and earn your Daily Research Points.