Opinion · Supreme Court of the United States
Muhammad v. Close
124 S. Ct. 1303
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 2004-02-25
- Topic
- general
holding that “requests for relief turning on circumstances of confinement may be presented in a § 1983 action” | holding that Heck is not “implicated by a prisoner’s challenge that threatens no consequence for his conviction or the duration of his sentence” | holding that § 1983 may be used to challenge disciplinary procedures where no accrued/earned good-time credits are taken as a sanction | holding that § 1983 may be used to challenge disciplinary procedures where no accrued/earned good-time credits are taken as a sanction | holding that Heck was inapplicable to prisoner’s claim alleging retaliatory prehearing lock- up, because claim did not necessarily imply invalidity of conviction or of loss of good-time credits | holding that a plaintiffs § 1983 suit challenging state prison disciplinary proceedings was not barred under Heck because it could not “be construed as seeking a judgment at odds with his conviction.” | holding that Heck was inapplicable to prisoner’s claim alleging retaliatory prehearing lockup, because claim did not necessarily imply invalidity of conviction or of loss of good-time credits | holding that Heck was inapplicable to prisoner’s claim alleging retaliatory prehearing lock- up, because claim did not necessarily imply invalidity of conviction or of loss of good-time credits | holding that Heck was inapplicable to prisoner’s claim alleging retaliatory prehearing lock- up, because claim did not necessarily imply invalidity of conviction or of loss of good-time credits | holding that this principle “applies just as soundly to federal prisoners filing” Bivens claims | holding that "[cjhallenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus” (citing Preiser v. Rodriguez, 411 U.S. 475, 500, 93 S.Ct. 1827, 36 L.Ed.2d 439 (1973 | recognizing, without deciding, that "[m]embers of the Court have expressed the view that unavailability of habeas for other reasons may also dispense with the Heck requirement." | recognizing, without deciding, that “[mjembers of the Court have expressed the view that unavailability of habeas for other reasons may also dispense with the Heck requirement.” | holding that “requests for relief turning on circumstances of confinement may be presented in a § 1983 action,” while “[c]hallenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus” | holding that while “[c]hallenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus; requests for relief turning on circumstances of confinement may be presented in a [civil rights] action.” | holding that while “[c]hallenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus; requests for relief turning on circumstances of confinement may be presented in a [civil rights] action.” | holding that Heck does not apply categorically to prison disciplinary proceedings | instructing that "[cjhallenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus” | stating that Heck bars § 1983 claims that implicitly question the validity of a conviction or the duration of a sentence | observing that “challenges to the validity of any confinement or to the particulars affecting its duration are the province of habeas corpus” | stating that Heck requires that “the litigant must first achieve favorable termination of his available state, or federal habeas, opportunities to challenge the underlying conviction or sentence.” | explaining that “requests for relief turning on circumstances of confinement” are the province of a civil rights action | noting that “Heck[] … is not … implicated by a prisoner’s challenge that threatens no consequence for his conviction or the duration of his sentence” | explaining that requests for relief turning on circumstance of confinement should
Citator
- Cited by
- 723 opinions
47 Fed. Appx. 738, reversed and remanded.
Muhammad then brought this § 1983 action, alleging that Close had charged him with threatening behavior (and subjected him to mandatory prehearing lockup) in retaliation for prior lawsuits and grievance proceedings against Close.Id., at 72. He amended his original complaint after obtaining counsel, and neither in his amended complaint nor at any subsequent juncture did Muhammad challenge his conviction for insolence, or the subsequent disciplinary action. See Brief for Petitioner 42. The amended complaint sought no expungement of the misconduct finding, and in fact Muhammad conceded that the insolence determination was justified. The only relief sought was $10,000 in compensatory and punitive damages "for the physical, mental and emotional injuries sustained" during the six days of prehearing detention mandated by the charge of threatening behavior attributable to Close's retaliatory motive. App. 72.
Following discovery, the Magistrate Judge recommended summary judgment for Close on the ground that Muhammad had failed to come forward with sufficient evidence of retaliation to raise a genuine issue of material fact as to that element.Id., at 63. The District Court adopted the recommendation.Id., at 70.
The factual error was compounded by following the mistaken view expressed in Circuit precedent thatHeckapplies 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 755his conviction or with the State's calculation of time to be served in accordance with the underlying sentence. That is, he raised no claim on which habeas relief could have been granted on any recognized theory, with the consequence thatHeck'sfavorable termination requirement was inapplicable.
The judgment of the Court of Appeals, accordingly, is reversed, and the case is remanded for consideration of summary judgment on the ground adopted by the District Court, and for any further proceedings consistent with this opinion.It is so ordered.Page 801
- Alphonse A. Gerhardsteinfiled a brief for the Prison Reform Advocacy Center asamicus curiaeurging reversal. ↩
- The assumption is that the incarceration that matters underHeckis the incarceration ordered by the original judgment of conviction, not special disciplinary confinement for infraction of prison rules. This Court has never followed the speculation inPreiserv.Rodriguez,411 U. S. 475,499(1973), that such a prisoner subject to "additional and unconstitutional restraints" might have a habeas claim independent of § 1983, and the contention is not raised by the State here. ↩
- Members of the Court have expressed the view that unavailability of habeas for other reasons may also dispense with theHeckrequirement. SeeHeckv.Humphrey,512 U. S. 477,491(1994) (SOUTER, J., concurring in judgment);Spencer v. Kemna,523 U. S. 1,21-22(1998) (GiNSBURG, J., concurring). This case is no occasion to settle the issue. ↩
- The Michigan Department of Corrections Policy Directive, No. 03.03.105 (June 6, 1994) (Directive), defines "Threatening Behavior" as "Words, actions or other behavior which expresses a[n] intent to injure or physically abuse another person." App. 40 (emphasis deleted). ↩
- The Directive defines "Insolence" as "Words, actions, or other behavior which is intended to harass, or cause alarm in an employee."Id., at 44 (emphasis deleted). ↩