Heck v. Humphrey

512 U.S. 477 (1994)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

P was convicted in state court of voluntary manslaughter for the killing of Rickie Heck, his wife, and is serving a 15-year sentence. While the appeal from his conviction was pending, P filed this suit in Federal District Court under 42 U.S.C. § 1983. P claimed James Humphrey and Robert Ewbank, Dearborn County prosecutors, and Michael Krinoph, an investigator with the Indiana State Police (Ds) acting under color of state law, had engaged in an 'unlawful, unreasonable, and arbitrary investigation' leading to P's arrest; 'knowingly destroyed' evidence 'which was exculpatory in nature and could have proved P's innocence'; and caused 'an illegal and unlawful voice identification procedure' to be used at P's trial. P sought compensatory and punitive monetary damages but did not ask for injunctive relief. P has not sought release from custody. The District Court dismissed without prejudice because the issues it raised 'directly implicate the legality of P's confinement.' While P's appeal to the Seventh Circuit was pending, the Indiana Supreme Court upheld his conviction and sentence on direct appeal. Also, P's first petition for a writ of habeas corpus in Federal District Court was dismissed because it contained unexhausted claims; and his second federal habeas petition was denied, and the denial was affirmed by the Seventh Circuit. The Seventh Circuit in the §1983 action affirmed and approved the reasoning of the District Court: If, regardless of the relief sought, P [in a federal civil rights action] is challenging the legality of his conviction, so if he won he would have to be released, thus his suit was for habeas corpus and P must exhaust his state remedies, on pain of dismissal if he fails to do so. P appealed.