The Heck Rule Against Collateral Attacks on a Conviction
What Is the Heck Doctrine?
In Heck v. Humphrey (1994) 512 U.S. 477, a man convicted of voluntary manslaughter brought a federal section 1983 suit against local officials who had investigated and prosecuted him, asserting they had engaged in unlawful acts that led to his arrest and conviction. (Heck, supra, 512 U.S. at pp. 478-479.)
Because the plaintiff's federal section 1983 claim impugned the validity of his criminal conviction, the high court analogized the situation to the common law tort action of malicious prosecution, which requires termination of the prior criminal proceeding in favor of the accused. This requirement avoids collateral attacks on the conviction, and avoids conflicting resolutions in different courts arising from the same facts. (Heck, supra, 512 U.S. at pp. 484-486.)
The Supreme Court continued:
"The hoary principle that civil tort actions are not appropriate vehicles for challenging the validity of outstanding criminal judgments applies to federal section 1983 damages actions that necessarily require the plaintiff to prove the unlawfulness of his conviction or confinement, just as it has always applied to actions for malicious prosecution." (Id. at p. 486.)
Thus, in order to maintain a claim for damages under federal section 1983 for harm caused by actions, which, if they were unlawful, would render a conviction invalid, the plaintiff must prove the conviction has been vacated, reversed, expunged or impugned by a grant of a writ of habeas corpus. (512 U.S. at p. 489.)