Preiser v. Rodriguez

Supreme Court of the United States · 1973 · Federal Courts

Federal CourtsHabeas CorpusSection 1983Exhaustion of State RemediesState Prisonershabeas corpus§ 1983exclusive federal remedy

Facts

The respondents were New York state prisoners who lost good-conduct-time credits through prison disciplinary proceedings. Each filed in federal district court under § 1983, alleging unconstitutional deprivation of those credits and seeking injunctive relief restoring them. Restoration of the credits would either immediately release them or shorten the length of their confinement. The prisoners had adequate state remedies available, but sought to avoid exhaustion by proceeding under § 1983.

Issue

May state prisoners use 42 U.S.C. § 1983 to obtain equitable relief restoring good-time credits when that relief would result in immediate release or speedier release from prison, or is federal habeas corpus their exclusive federal remedy, requiring exhaustion of state remedies?

Rule

When a state prisoner challenges the very fact or duration of physical imprisonment, and seeks a determination entitling him to immediate release or a speedier release, his sole federal remedy is a writ of habeas corpus. In that circumstance, the prisoner must satisfy the habeas statute's exhaustion requirement if adequate state remedies are available.

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

Devon Pike is serving a state prison sentence in Ohio. After a disciplinary hearing at a prison near Toledo, officials revoke 120 days of earned release credits, and Devon files in federal district court under 42 U.S.C. § 1983 seeking an injunction restoring the credits so his release date will move up by four months.

What is the strongest argument that the federal court should reject Devon's use of § 1983 for this claim?

Explanation. When a state prisoner challenges the very fact or duration of physical imprisonment and seeks immediate or speedier release, the claim falls within the core of habeas corpus. Under the majority opinion, the more specific habeas statute displaces § 1983 for that relief, and the prisoner must satisfy habeas exhaustion if adequate state remedies are available.