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In Heck v. Humphrey, 512 U.S. 477 (1994), the United States Supreme Court considered whether a state prisoner could use a civil action under 42 U.S.C. § 1983 to seek money damages based on claims that would call a criminal conviction into question. The case involved questions about the point at which a civil rights claim could move forward when the person bringing the claim remained subject to a conviction that had not been set aside in any court. The Court reviewed the interaction between the federal civil rights statute and the federal habeas corpus statute and explained how federal courts should handle damages claims tied to an outstanding state conviction.
Background Facts
Roy Heck was convicted in Indiana state court of voluntary manslaughter for the death of his wife. He received a 15-year sentence. While his direct appeal was still pending in the Indiana courts, Heck filed a civil action in the United States District Court under 42 U.S.C. § 1983. His complaint named prosecutors and a state police investigator as defendants. Heck claimed that they engaged in unlawful acts that led to his arrest and conviction. He alleged that the investigators carried out an improper investigation, destroyed evidence that he stated could have helped him, and conducted an illegal voice identification procedure. He sought money damages. He did not seek release from custody or any injunctive relief.
The District Court dismissed the civil case without prejudice, finding that Heck’s claims directly questioned the legality of his confinement. While his appeal from that dismissal was pending, the Indiana Supreme Court affirmed his conviction. Heck then filed two federal habeas corpus petitions, and both were denied. After those denials, the Seventh Circuit affirmed the dismissal of his § 1983 action. It agreed that a federal damages action could not proceed if success in that action would call the conviction into question unless the conviction had already been set aside through direct appeal, habeas relief, or other recognized procedures.
Issue
Whether a state prisoner could recover damages under § 1983 when the success of that civil claim would imply that the person’s outstanding conviction was invalid, even though the conviction had not been reversed, vacated, expunged, or called into question by a habeas court.
Holding
The Court held that a § 1983 plaintiff may not recover damages for an unconstitutional conviction, unlawful imprisonment, or other harm tied to acts that would render the conviction invalid unless the conviction had first been reversed on direct appeal, expunged, declared invalid by a state tribunal, or questioned by the issuance of a writ of habeas corpus. If a civil claim, even when framed as a damages claim, would imply the invalidity of the conviction, the claim could not go forward while the conviction remained in place.
Rationale
The Court explained that § 1983 does not contain an exhaustion requirement, but this case did not turn on exhaustion. Instead, it turned on whether the cause of action existed at all. The Court looked to common-law tort principles as a starting point, noting that malicious prosecution claims required a showing that the prior criminal proceeding ended in favor of the accused. That requirement existed to prevent inconsistent results and to avoid the use of civil suits as indirect challenges to criminal judgments.
Relying on this principle, the Court reasoned that civil rights claims under § 1983 could not serve as vehicles to attack outstanding convictions. A judgment for the plaintiff in such a case would create a conflict with the criminal judgment still in place. Because federal courts have long refused to allow collateral attacks on criminal convictions through civil actions, the Court concluded that a plaintiff must first obtain a ruling that set aside the conviction before seeking damages connected to that conviction.
The Court also explained that this approach avoided interference with the habeas process. Congress required state prisoners to use habeas corpus when challenging the fact or length of confinement. Permitting a § 1983 damages action that implied the conviction was invalid, without first requiring habeas relief, would undermine that structure. The Court therefore held that a § 1983 cause of action for damages tied to a conviction does not arise until the conviction has been invalidated.
Applying this rule, Heck’s claim could not proceed because both the District Court and the Court of Appeals found that his allegations directly challenged the legality of his conviction, and no court had set that conviction aside.
Conclusion
Heck v. Humphrey set an important limit on the use of § 1983 by people seeking damages tied to criminal convictions. The decision required a person to show that the conviction had already been set aside before seeking damages that implied the conviction was invalid. Without that showing, the civil claim could not move forward. This rule still guides courts in cases where civil rights plaintiffs seek compensation for harm tied to an alleged wrongful conviction.
If your conviction was overturned based on new evidence or a court ruling that called the original proceedings into question, a New York wrongful convictions lawyer at Stephen Bilkis & Associates can guide you through your options for filing a civil action.