Heck v. Humphrey
The Court ruled that a state prisoner cannot sue for damages under the federal civil rights law over an allegedly unconstitutional conviction unless he first gets that conviction reversed, expunged, or otherwise invalidated through appeal, executive action, or habeas corpus.
The decision creates a new gatekeeping rule for prisoner lawsuits, preventing inmates from using civil damages suits as a backdoor way to challenge convictions that are still legally valid, and channels those challenges instead through appeals and habeas corpus.
“A claim for damages bearing that relationship, to a conviction or sentence that has not been so invalidated is not cognizable under §1983.”
The Court's core rule barring damages suits that would undermine an unreversed conviction.
How it got here: A federal trial court dismissed Heck's damages suit without prejudice, the Seventh Circuit affirmed on habeas-exhaustion grounds, and Heck asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Roy Heck was convicted in Indiana state court of killing his wife and sentenced to 15 years. While his direct appeal was pending, he sued state prosecutors and a police investigator for money damages, claiming they ran an unlawful investigation, destroyed evidence that could have proven his innocence, and used an improper identification procedure at his trial.
The question before the Court
Could a man serving a prison sentence sue the officials who investigated his case for money damages, by arguing the investigation made his conviction unconstitutional, without first getting that conviction thrown out?
The Court's answer
No — the Court ruled that a state prisoner cannot collect money damages under the federal civil rights law for an allegedly unconstitutional conviction or imprisonment unless he first gets that conviction or sentence reversed on appeal, expunged, declared invalid by a state court, or undermined through a successful federal habeas corpus case. Until that happens, the damages claim simply doesn't exist as a matter of law.
The Court reached this rule by treating §1983 suits like tort claims and borrowing the old rule from malicious-prosecution lawsuits, which likewise require the earlier criminal case to have ended in the plaintiff's favor before a person can sue over it. Because Heck's claims would necessarily call his still-valid manslaughter conviction into question, and he hadn't shown it was overturned, his suit could not proceed.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Prisoners who believe police or prosecutors violated their rights during an investigation or trial can't collect damages for that misconduct while still serving time under a conviction that hasn't been overturned. This pushes inmates toward appeals and habeas petitions first, and shields officials and states from damages suits that would effectively second-guess an unreversed criminal judgment.
What changes now
The ruling is final on the legal question, though it leaves Heck free to refile a damages suit if he later succeeds in overturning his conviction on appeal or through habeas corpus. The decision sets a standing rule that lower federal courts must now apply whenever a state prisoner's damages suit would necessarily call a conviction's validity into question, screening out such suits until the conviction is actually invalidated.
What this does not decide
The Court did not decide how its rule applies to people who are no longer in custody and thus cannot pursue habeas corpus, and it left open whether abstention or claim-preclusion doctrines might separately affect a prisoner's civil-rights suit filed during ongoing criminal proceedings.
Concurrences and dissents
How the Justices voted
Majority (1). Justice Scalia (author).
Separate writings (1). Justice Thomas (author of a concurrence).
Concurrence — Justice Thomas
Justice Thomas joined the Court's opinion in full but wrote separately to observe that it was the Court itself, through past decisions expanding both habeas corpus and §1983 beyond their original scope, that created the conflict between the two statutes. He argued that because the Court created the tension, it was appropriate for the Court to resolve it, and found the majority's approach principled. Read the full concurrence →
Concurrence — Justice Souter
Justice Souter agreed with the outcome but objected to grounding the rule in the common-law tort of malicious prosecution, arguing that tort's other elements (like proving lack of probable cause) don't transfer sensibly into §1983 and that damages for wrongful conviction weren't even available under that tort historically. He would instead derive the rule directly from harmonizing §1983 with the habeas statute's exhaustion policy, and he stressed the rule should apply only to prisoners still in custody, not to people who can no longer seek habeas relief.
How the Court got there
The legal reasoning, step by step
- The Court explained that a federal civil-rights damages suit under 42 U.S.C. §1983 functions like a tort claim, so it looked to common-law tort rules as a starting point for deciding what such a claim requires.
- It found the closest common-law analogy to be the old tort of malicious prosecution, which — unlike false-arrest claims — allows damages for confinement carried out under legal process, but only if the earlier criminal case ended in the accused's favor.
- That favorable-termination rule exists to prevent a civil lawsuit from becoming a backdoor way to relitigate guilt and to avoid two courts reaching conflicting conclusions about the same conviction, a concern the Court said applies equally to §1983 suits.
- Applying that principle, the Court held that whenever winning a §1983 damages claim would necessarily prove a conviction or sentence invalid, the claim doesn't exist as a legal matter until the conviction or sentence has actually been reversed, expunged, declared invalid by a state tribunal, or undermined by a federal habeas ruling.
- The Court distinguished this from its earlier decision in Preiser v. Rodriguez, which addressed prisoners seeking release rather than damages, and concluded that Preiser's passing comments about damages suits were unreliable guidance for this different question.
- Because both lower courts had already found that Heck's damages claims necessarily challenged the validity of his still-standing conviction, and he had not shown that conviction had been overturned, the Court concluded his claim was not yet legally cognizable.
Doctrinal impact
Cases affected by this decision
Limits Preiser v. Rodriguez (411 U. S. 475)
The Court called Preiser's comments about damages suits unreliable dicta and confined its holding to release-from-custody claims.
Distinguishes Wolff v. McDonnell (418 U. S. 539)
The Court said Wolff's damages claim was about wrong procedures, not about invalidating a conviction, so it doesn't control here.