In Heck v. Humphrey, 512 U.S. 477, 114 S. Ct. 2364, 129 L. Ed. 2d 383 (1994), the defendant brought a Section 1983 action against state officials alleging they improperly investigated his crime and destroyed evidence. The Supreme Court rejected the defendant's constitutional claims, holding "civil tort actions are not appropriate vehicles for challenging the validity of outstanding criminal judgments." Id. at 486. The Court further explained that where the basis for the constitutional claims would require proof of the invalidity of the underlying conviction, a civil rights action cannot be maintained unless the conviction or sentence was invalidated. Id. at 487.