Heck v. Humphrey

Supreme Court of the United States · 1994 · Torts

TortsSection 1983Habeas CorpusPrisoner Litigation42 U.S.C. § 198328 U.S.C. § 2254damagesconviction invalidity

Facts

Roy Heck was convicted in Indiana state court of voluntary manslaughter for killing his wife and was serving a 15-year sentence. While his direct appeal was pending, he filed a pro se § 1983 suit seeking compensatory and punitive damages against two county prosecutors and a state police investigator. He alleged an unlawful investigation leading to his arrest, knowing destruction of exculpatory evidence, and use of an illegal voice-identification procedure at trial. He did not seek injunctive relief or release from custody in this action.

Issue

May a state prisoner recover damages under § 1983 for alleged unconstitutional acts leading to his conviction when success on the damages claim would necessarily imply the invalidity of that conviction, but the conviction has not been reversed or otherwise invalidated?

Rule

To recover damages for an allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the conviction or sentence has already been reversed on direct appeal, expunged by executive order, declared invalid by an authorized state tribunal, or called into question by issuance of a federal writ of habeas corpus. If a judgment for the plaintiff in the § 1983 action would necessarily imply the invalidity of an outstanding conviction or sentence, the claim is not cognizable under § 1983 unless and until that favorable termination occurs; if success would not necessarily imply invalidity, the action may proceed.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, Devin Morales is serving a state sentence for burglary. He files a federal § 1983 action for compensatory and punitive damages against Detective Nora Vance, alleging she fabricated a witness statement and that the fabricated evidence was used to secure his conviction; his conviction has not been reversed or otherwise set aside.

Should the federal court allow Devin's damages action to proceed?

Explanation. The majority held that a § 1983 plaintiff seeking damages for allegedly unconstitutional conviction or imprisonment, or for harm caused by actions whose unlawfulness would render the conviction or sentence invalid, must first show favorable termination. The court asks whether success would necessarily imply the invalidity of the outstanding conviction. Here, proving fabricated evidence secured the conviction would do so, so the claim must be dismissed unless the conviction has already been reversed, expunged, declared invalid, or called into question by federal habeas. (Derived from Heck v. Humphrey (n.d.).)