Heck v. Humphrey

PETITIONER: Roy Heck
RESPONDENT: James Humphrey, Dearborn County Prosecutor, et al.
LOCATION: Heck Residence

DOCKET NO.: 93-6188
DECIDED BY: Rehnquist Court (1993-1994)
LOWER COURT: United States Court of Appeals for the Seventh Circuit

CITATION: 512 US 477 (1994)
ARGUED: Apr 18, 1994
DECIDED: Jun 24, 1994
GRANTED: Jan 14, 1994

ADVOCATES:
Charles A. Rothfeld - on behalf of the Petitioner
Matthew R. Gutwein - on behalf of the Respondents

Facts of the case

Roy Heck was convicted of voluntary manslaughter for the death of his wife in Indiana state court and sentenced to 15 years in prison. He filed an action in federal district court claiming that the prosecution engaged in an “unlawful, unreasonable, and arbitrary investigation” before his arrest and knowingly destroyed favorable evidence. Heck sought compensatory and punitive damages under 42 U.S.C. §1983, but did not seek a release from custody. The district court dismissed the action. While his appeal to the U.S. Court of Appeals for the Seventh Circuit was pending, the Indiana Supreme Court affirmed his conviction and sentence. Heck’s petition for habeas corpus was denied. The Seventh Circuit affirmed the dismissal of Heck’s damages action, stating that the action challenged the legality of the conviction, so Heck must exhaust all state remedies before seeking §1983 relief like he would under the habeas corpus statute.

Question

(1) Can a state prisoner attacking the legality of his conviction circumvent the habeas corpus exhaustion requirement by filing an action under 42 U.S.C. § 1983 and confining his prayer for relief to a declaratory judgment and money damages?

(2) Should a state prisoner's action attacking the legality of his conviction that includes unexhausted claims be dismissed without prejudice?

Media for Heck v. Humphrey

Audio Transcription for Oral Argument - April 18, 1994 in Heck v. Humphrey

Audio Transcription for Opinion Announcement - June 24, 1994 in Heck v. Humphrey

William H. Rehnquist:

The opinion of the Court in No. 93-6188, Heck against Humphrey will be announced by Justice Scalia.

Antonin Scalia:

This case comes to us on certiorari from the United States Court of Appeals for the Seventh Circuit.

Petitioner, Roy Heck, killed his wife in Indiana.

A State Court convicted him of voluntary manslaughter and sentenced him to 15 years in prison.

While the direct appeal from his conviction was pending, Heck proceeding without the assistance of a lawyer filed this lawsuit in Federal District Court under he Civil Rights Act of 1871, 42 U.S.C. Section 1983.

Heck's complaint sought money damages but not injunctive relief or release from custody, on the claim that respondents, three state officials who had assisted in the criminal investigation had engaged in unlawful acts leading to Heck's arrest and conviction.

The District Court dismissed his action without prejudice and the Court of Appeals affirmed the dismissal holding that if the plaintiff in a federal civil rights action is challenging the legality of his conviction so that his victory would require his release even if he had not expressly sought that relief.

The suit must be classified as a habeas corpus action and dismissed if the plaintiff has failed to exhaust his available state remedies.

We granted certiorari and now affirm but on grounds somewhat different from those relied on by the lower courts.

Section 1983 creates a species of tort liability and we have said in the past that the characteristics of Section 1983 will be shaped by the common law of torts as it existed when the statute was enacted.

The common law has always recognized the principle that civil tort actions are not appropriate vehicles for challenging the validity of outstanding criminal judgments.

An action for malicious prosecution, for example, which provides the closest analogy to claims of the type considered here, requires the plaintiff to allege and prove termination of the prior criminal proceeding in his favor.

This Court has long expressed similar concerns about the finality and consistency of judgments and hence, has been disinclined to expand opportunities for collateral attack on criminal convictions.

We think those same common law principles applied to Section 1983 suits.

When a state prisoner seeks damages in such a suit, the District Court must consider whether a judgment in his favor would necessarily imply the invalidity of his conviction or sentence.

If so, the complaint must be dismissed unless the conviction 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.

If, on the other hand, a favorable judgment for the plaintiff in the Section 1983 tort action would not imply the invalidity of the conviction or sentence, the action should be allowed to proceed absent some other bar to suit.

Although the issue in cases such as this is not, therefore, the exhaustion of state remedies, the dismissal of Heck's 1983 action was correct because the courts below both found that his damages claims challenge the legality of his conviction.

Justice Thomas has filed a concurring opinion; Justice Souter, joined by Justices Blackmun, Stevens and O'Connor has filed an opinion concurring in the judgment.