Opinion · Supreme Court of the United States

Muhammad v. Close

540 U.S. 749

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
2004-02-25
Topic
general

How later courts describe this case

  • 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 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 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 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."

Citator

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Cited by
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Headnotes

  1. Civil Rights Law — Section 1983 Federal law provides two main avenues of relief for complaints related to imprisonment: challenges to the validity of confinement or to particulars affecting its duration must be brought by petition for habeas corpus, while requests for relief turning on the circumstances of confinement may be brought under 42 U.S.C. § 1983. 540 U.S. 749 (citing Preiser v. Rodriguez, 411 U.S. 475, 500 (1973))
  2. Civil Rights Law — Heck v. Humphrey Requirement Where success in a prisoner's § 1983 damages action would implicitly question the validity of his conviction or the duration of his sentence, the litigant must first achieve favorable termination of his available state, or federal habeas, opportunities to challenge the underlying conviction or sentence. 540 U.S. 749 (citing Heck v. Humphrey, 512 U.S. 477 (1994))
  3. Civil Rights Law — Application of Heck Heck's favorable termination requirement extends to a § 1983 action claiming damages and equitable relief for a procedural defect in a prison's administrative process where the administrative action taken against the plaintiff could affect credits toward release based on good time served. 540 U.S. 749 (citing Edwards v. Balisok, 520 U.S. 641 (1997))
  4. Civil Rights Law — Heck Requirement Not Implicated A prisoner's § 1983 challenge that threatens no consequence for his conviction or the duration of his sentence does not implicate Heck's requirement to resort to state litigation and federal habeas before proceeding under § 1983, because there is no need to preserve the habeas exhaustion rule and no impediment under Heck in such a case. 540 U.S. 749
  5. Civil Rights Law — Disciplinary Proceedings Prison disciplinary determinations do not, as such, raise any implication about the validity of the underlying conviction; 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, and the effect of disciplinary proceedings on good-time credits is a matter of state law or regulation. 540 U.S. 749
  6. Civil Rights Law — Habeas Relief Unavailable Where a prisoner raises no claim on which habeas relief could have been granted on any recognized theory, Heck's favorable termination requirement is inapplicable to his § 1983 action. 540 U.S. 749
  7. Civil Procedure — Waiver A party who had every opportunity to challenge a magistrate judge's position in the District Court and in the Court of Appeals, but failed to raise the claim when its legal and factual premises could have been litigated, cannot raise that contention for the first time in the Supreme Court. 540 U.S. 749 (citing Auer v. Robbins, 519 U.S. 452, 464 (1997))
MUHAMMAD v. CLOSE,540 U.S. 749(2004)
124 S.Ct. 1303
MUHAMMAD, AKA MEASE v. CLOSE.
No. 02-9065.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
SIXTH CIRCUIT
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 under42 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.Heckhas 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 byHeckbecause Muhammad had sought expungement of the misconduct charge from the prison record when he could seek such relief only after satisfyingHeck'sfavorable 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 suchPage 750relief. This error was compounded by the court's mistaken view thatHeckapplies categorically to all suits challenging prison disciplinary proceedings. The administrative determinations here do not raise any implication about the conviction's validity and do not necessarily affect the duration of time to be served. 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 such credits were eliminated by the challenged prehearing action. Because Muhammad raised no claim on which habeas relief could have been granted,Heck'sfavorable termination requirement does not apply. Having previously failed to challenge the Magistrate Judge's decision that good-time credits were not affected by the allegedly retaliatory overcharge of threatening behavior and consequential prehearing detention, Close has waived the 11th-hour contention thatHeckis squarely on point.

47 Fed. Appx. 738, reversed and remanded.
Corinne Beckwith, by appointment of the Court,539 U. S. 925, argued the cause for petitioner. With her on the brief wereJames W. Klein, Samia Fam, andGiovannaShay.Thomas L. Casey, Solicitor General of Michigan, argued the cause for respondent. With him on the briefs wereMichael A. Cox, Attorney General, andLinda M.OlivieriandKevin Himebaughfn*
PER CURIAM.
I
Federal law opens two main avenues to relief on complaints related to imprisonment: a petition for habeas corpus,28 U. S. C. § 2254, and a complaint under the Civil Rights Act of 1871, Rev. Stat. § 1979, as amended,42 U. S. C. § 1983. Challenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus,Preiser v. Rodriguez,411 U. S. 475,500(1973); requests for relief turning on circumstances of confinement may be presented in a § 1983 action. Some cases are hybrids, with aPage 751prisoner seeking relief unavailable in habeas, notably damages, but on allegations that not only support a claim for recompense, but imply the invalidity either of an underlying conviction or of a particular ground for denying release short of serving the maximum term of confinement. InHeckv.Humphrey,512 U. S. 477(1994), we held that where success in a prisoner's § 1983 damages action would implicitly question the validity of conviction or duration of sentence, the litigant must first achieve favorable termination of his available state, or federal habeas, opportunities to challenge the underlying conviction or sentence. Accordingly, inEdwards v. Balisok,520 U. S. 641(1997), we appliedHeckin the circumstances of a § 1983 action claiming damages and equitable relief for a procedural defect in a prison's administrative process, where the administrative action taken against the plaintiff could affect credits toward release based on good time served. In each instance, conditioning the right to bring a § 1983 action on a favorable result in state litigation or federal habeas served the practical objective of preserving limitations on the availability of habeas remedies. Federal petitions for habeas corpus may be granted only after other avenues of relief have been exhausted.28 U.S.C. § 2254(b)(1)(A). SeeRosev.Lundy,455 U.S. 509(1982). Prisoners suing under § 1983, in contrast, generally face a substantially lower gate, even with the requirement of the Prison Litigation Reform Act of 1995 that administrative opportunities be exhausted first.42 U. S. C. § 1997e(a).Heck'srequirement to resort to state litigation and federal habeas before § 1983 is not, however, implicated by a prisoner's challenge that threatens no consequence for his conviction or the duration of his sentence.1There is no need toPage 752preserve the habeas exhaustion rule and no impediment underHeckin such a case, of which this is an example.2
II
A
This suit grew out of a confrontation between petitioner, Muhammad, an inmate, and the respondent Michigan prison official, Close. App. 70. According to his amended complaint, Muhammad was eating breakfast when he saw Close "staring at him through the hallway window."Id., at 71. Eventually Muhammad stared back, provoking Close to assume "a fighting stance" and "com[e] into the dining area at a fast pace with his face contorted."Ibid.Muhammad stood up and faced him, and when the two were within a foot of one another, Close asked, "whats[sic]up," all the while "staring angerly[sic]." In the aftermath of the confrontation, Muhammad was handcuffed, taken to a detention cell, and charged with violating the prison rule prohibiting "Threatening Behavior." (Emphasis deleted.)3Under the rules, special detention was required prior to a hearing on the charge, which occurred six days later. Muhammad was acquitted of threatening behavior, but found guilty of the lesser infraction of insolence, for which prehearing detention would not have been mandatory.4Ibid.Muhammad wasPage 753required to serve an additional 7 days of detention and deprived of privileges for 30 days as penalties for insolence.Ibid.

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.
B
Muhammad then appealed to the United States Court of Appeals for the Sixth Circuit, which, by an opinion designated not for publication, affirmed the summary judgment for Close, though not on the basis recommended by the Magistrate Judge and adopted by the District Court. 47 Fed. Appx. 738 (2002). Instead of considering the conclusion that Muhammad had produced inadequate evidence of retaliation, a ground that would have been dispositive if sustained, the Court of Appeals held the action barred byHeckbecause Muhammad had sought, among other relief, the expungementPage 754of the misconduct charge from the prison record. Relying upon Circuit precedent, seeHuey 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 satisfyingHeck'sfavorable termination requirement. The Circuit thus maintained a split on the applicability ofHeckto 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. SeeLearner v. Fauver,288 F. 3d 532,542-544(CA3 2002);DeWaltv.Carter,224 F. 3d 607,613(CA7 2000);Jenkins v. Haubert,179 F. 3d 19,27(CA2 1999);Brown v. Plant,131 F. 3d 163,167-169(CADC 1997). We granted certiorari to resolve the conflict,539 U. S. 925(2003), and now reverse.
III
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 over-looked the amended complaint that sought no such relief.

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.
IV
Close tries to salvage the appellate court's judgment by arguing for the first time here thatHeckis squarely on point because, if the § 1983 suit succeeded, Muhammad would be entitled to restoration of some good-time credits with the result of less time to be spent in prison. Brief for Respondent 17-18. But this eleventh-hour contention was waived. The Magistrate Judge's report stated that good-time credits were not affected by the allegedly retaliatory overcharge of threatening behavior and the consequential prehearing detention Muhammad complained of, and Close had every opportunity to challenge the Magistrate Judge's position in the District Court and in the Court of Appeals. Having failed to raise the claim when its legal and factual premises could have been litigated, Close cannot raise it now. SeeAuerv.Robbins,519 U. S. 452,464(1997).

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
  1. Alphonse A. Gerhardsteinfiled a brief for the Prison Reform Advocacy Center asamicus curiaeurging reversal. ↩
  2. 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. ↩
  3. 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. ↩
  4. 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). ↩
  5. 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). ↩