LOCATION:Guantanamo Bay, Cuba
DOCKET NO.: 02-9065
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit
CITATION: 540 US 749 (2004)
GRANTED: Jun 16, 2003
ARGUED: Dec 01, 2003
DECIDED: Feb 25, 2004
Alphonse A. Gerhardstein – for the Prison Reform Advocacy Center as amicus curiae urging reversal
Corinne A. Beckwith – argued the cause for Petitioner
Thomas L. Casey – argued the cause for Respondent
Facts of the case
Prison officials sentenced Muhammad, a state prisoner, to seven days of special detention and 30 days of restricted privileges for insolence toward Close, a prison guard. Muhammad filed suit with a magistrate judge under section 1983 of the Civil Rights Act of 1871, seeking $10,000 in damages. Muhammad alleged Close had charged him with threatening behavior in retaliation for other proceedings against Close. Muhammad did not challenge his insolence conviction or punishment. The magistrate judge ruled that Muhammad lacked evidence proving Close acted in retaliation. The U.S. District Court agreed.
The U.S. Court of Appeals affirmed the ruling for a different reason, citing the U.S. Supreme Court decision Heck v. Humphrey (1994). In Heck the Court held that when a prisoner seeks damages in a case that questions his sentence, the prisoner must first have successfully challenged the sentence itself or the conviction itself. The Court of Appeals held that because Muhammad’s damages case questioned his sentence, he must first successfully appeal the sentence itself. Going further the Court of Appeals held that Heck applies to all challenges to prison disciplinary proceedings.
Does the U.S. Supreme Court’s decision in Heck v. Humphrey (1994) require that prisoners who challenge prison disciplinary proceedings – but whose suits do not question their sentences’ validity – first successfully challenge their sentences?
Media for Muhammad v. Close
Audio Transcription for Opinion Announcement – February 25, 2004 in Muhammad v. Close
William H. Rehnquist:
The second case which I have to announce is No. 02-9065.
This case comes to us on a writ of certiorari to the Court of Appeals for the Sixth Circuit.
The petitioner Muhammad is a state prisoner.
He brought this 1983 action alleging that a prison officer had charged him with threatening behavior and subjected him to mandatory pre-hearing lock up in retaliation for prior lawsuits and grievance proceedings against the officer.
The amended complaint sought money damages solely for the physical, mental, and emotional injuries sustained during the six days of pre-hearing detention.
The District Court awarded summary judgment to the officer.
Muhammad appealed to the United States Court of Appeals for the Sixth Circuit which affirmed the summary judgment on the ground that the action was barred by a favorable termination requirement set out in a 1994 decision in Heck against Humphrey.
In the unanimous Per Curiam filed today with the Clerk of the Court, we reverse and remand finding that the Court of Appeals made two mistakes.
It mistakenly assumed that Muhammad sought expungement of his misconduct charge, but such a request is absent from his amended complaint.
It also relied on Circuit precedent for the proposition that the favorable termination requirement applies categorically to all suits challenging prison disciplinary proceedings.
We hold that Heck’s rule is trigged only where a judgment would raise an implication about the validity of extent of an underlying conviction although, prison disciplinary proceedings may do just that by bearing on the award of revocation of good time credits, for example.
That is not necessarily so.
In this case, Muhammad raised no claim on which habeas relief could have granted on any recognized theory with the consequence that Heck’s rule was inapplicable.
So, we reverse the judgment of the Court of Appeals.
It is unanimous.