Heck v. Humphrey

1994-06-24

Headline: Convicted state prisoners cannot recover damages in federal civil-rights suits unless their conviction or sentence has first been overturned, expunged, or invalidated, forcing habeas or appeal first and limiting immediate money claims.

Holding: The Court held that a convicted state prisoner cannot recover money damages in a federal civil-rights suit for unlawful conviction or imprisonment unless the conviction or sentence has first been reversed, expunged, declared invalid, or called into question by habeas.

Real World Impact:

Bars damages claims that would necessarily invalidate a conviction unless conviction is first overturned.
Requires prisoners to secure reversal or habeas relief before seeking federal civil-rights money damages.
Stops many civil-rights suits from proceeding and pauses statute-of-limitations until invalidation.

Topics: prisoner civil-rights, money damages after conviction, habeas corpus and appeals, finality of convictions

Summary

Background

Roy Heck, a man convicted in Indiana of voluntary manslaughter and serving a 15-year sentence, sued two county prosecutors and a state police investigator under 42 U.S.C. § 1983. While his direct appeal was pending, Heck (acting pro se) alleged an unlawful investigation, destruction of exculpatory evidence, and an illegal voice-identification procedure at trial, and sought compensatory and punitive money damages but not release from custody. The federal District Court dismissed the suit as implicating the legality of his confinement; the Seventh Circuit affirmed after state and federal habeas proceedings failed to overturn his conviction, and the Supreme Court granted review.

Reasoning

The Court examined the overlap between federal civil-rights lawsuits under § 1983 and habeas corpus petitions that challenge custody. Relying on the policy against collateral attacks on criminal judgments and on common-law tort analogies, the Court concluded that a damages claim is not available under § 1983 when success would necessarily imply the invalidity of a conviction or sentence. In those cases, the prisoner must first have the conviction or sentence reversed, expunged, declared invalid by a state tribunal, or called into question by a federal court’s issuance of a writ of habeas corpus.

Real world impact

The ruling means convicted state prisoners cannot obtain money damages in federal § 1983 suits when a favorable judgment would invalidate their convictions unless the conviction has already been invalidated. District courts should dismiss such claims otherwise. The Court also explained that the damage claim does not accrue until the conviction is invalidated. Claims that do not necessarily imply invalidity (for example, some unlawful searches) may proceed under § 1983.

Dissents or concurrances

Justices Thomas and Souter wrote separate opinions concurring in the judgment. They agreed with the result but emphasized different points about how § 1983 should be read with the habeas statute and the role of common-law analogies.