OCTOBER TERM, 2003
certiorari to the united states court of appeals for the sixth circuit
No. 02-9065. Argued December 1, 2003—Decided February 25, 2004
Under federal law, challenges to the validity of confinement or its duration are the province of habeas corpus, but requests for relief turning on confinement circumstances may be raised under 42 U. S. C. § 1983. Where a prisoner's § 1983 action would implicitly question the conviction's validity or sentence's duration, the litigant must first achieve favorable termination of his available state, or federal habeas, opportunities to challenge the underlying conviction or sentence. Heck v. Humphrey, 512 U. S. 477. Heck has been applied in a § 1983 challenge to a prison's administrative action that could affect a prisoner's credits toward release based on good time served, Edwards v. Balisok, 520 U. S. 641, but is not implicated by a challenge that threatens no consequence for a prisoner's conviction or his sentence's duration. Here, prison rules required prehearing detention when petitioner Muhammad, an inmate, was charged with "threatening behavior" in the aftermath of a confrontation with respondent Close, a prison official. Muhammad was acquitted of threatening behavior at a hearing six days later, but was found guilty of insolence, for which prehearing detention would not have been mandatory. He then filed this § 1983 action, alleging that Close had charged him with threatening behavior (subjecting him to prehearing lockup) in retaliation for prior lawsuits and grievance proceedings against Close. His amended complaint did not challenge his insolence conviction, or the hearing, and did not seek to expunge the misconduct finding, seeking only damages for alleged physical, mental, and emotional injuries sustained during his prehearing detention. Accepting the Magistrate Judge's recommendation, the District Court granted Close summary judgment on the ground that Muhammad had failed to present sufficient evidence of retaliation to raise a material fact as to that element. In affirming, the Sixth Circuit found the action barred by Heck because Muhammad had sought expungement of the misconduct charge from the prison record when he could seek such relief only after satisfying Heck's favorable termination requirement.
Held: The Sixth Circuit's decision was flawed as a matter of fact and as a matter of law. In making the erroneous factual finding that Muhammad had sought to expunge the misconduct charge from his prison record, the court simply overlooked his amended complaint that sought no such
749Page: Index 1 2 3 4 5 6 7 Next
Last modified: October 4, 2007