ment of the misconduct charge from the prison record. Relying upon Circuit precedent, see Huey v. Stine, 230 F. 3d 226 (2000), the Court of Appeals held that an action under § 1983 to expunge his misconduct charge and for other relief occasioned by the misconduct proceedings could be brought only after satisfying Heck's favorable termination requirement. The Circuit thus maintained a split on the applicability of Heck to prison disciplinary proceedings in the absence of any implication going to the fact or duration of underlying sentence, four Circuits having taken the contrary view. See Leamer v. Fauver, 288 F. 3d 532, 542-544 (CA3 2002); DeWalt v. Carter, 224 F. 3d 607, 613 (CA7 2000); Jenkins v. Haubert, 179 F. 3d 19, 27 (CA2 1999); Brown v. Plaut, 131 F. 3d 163, 167-169 (CADC 1997). We granted certiorari to resolve the conflict, 539 U. S. 925 (2003), and now reverse.
The decision of the Court of Appeals was flawed as a matter of fact and as a matter of law. Its factual error was the assumption that Muhammad sought to expunge the misconduct charge from his prison record. The court simply overlooked the amended complaint that sought no such relief.
The factual error was compounded by following the mistaken view expressed in Circuit precedent that Heck applies categorically to all suits challenging prison disciplinary proceedings. But these administrative determinations do not as such raise any implication about the validity of the underlying conviction, and although they may affect the duration of time to be served (by bearing on the award or revocation of good-time credits) that is not necessarily so. The effect of disciplinary proceedings on good-time credits is a matter of state law or regulation, and in this case, the Magistrate Judge expressly found or assumed that no good-time credits were eliminated by the prehearing action Muhammad called in question. His § 1983 suit challenging this action could not therefore be construed as seeking a judgment at odds withPage: Index Previous 1 2 3 4 5 6 7 Next
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