Case Citator › Heck v. Humphrey

Heck v. Humphrey

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
512 U.S. 477
Decided
Confirmed treatments
5
Flagged citations read
1,038 of 1,039
Citing cases (total)
15,263
Treatment dates
1998–2022
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Heck v. Humphrey is limited: 1,038 of the 1,039 flagged citations have been read, the text of the other one could not be retrieved, and the 5 confirmed treatments are listed below. Zupan v. Brown, White v. Phillips, Dible v. Scholl, Wilson v. Johnson, and Farmer v. County of Westchester declined to extend Heck's favorable-termination bar where habeas relief was legally or practically unavailable.
More on how this was screened

The other reviewed courts applied Heck's own necessarily-implies-invalidity boundary, rejected adverse arguments, or placed nearby treatment language on a conviction, another precedent, or a procedural ruling. Wallace v. Kato applied Heck's existing-conviction boundary rather than adversely treating it. Because that one opinion remains unread, the review is not complete and the case is still in review.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

15,263 later cases cite Heck v. Humphrey; 1,039 of those citations sat close to treatment language and were flagged for reading; 1,038 of them have been read, and the text of 1 citing opinion could not be retrieved, so it remains unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Heck v. Humphrey?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Northern District of California held that Heck's favorable-termination requirement does not apply when a former prisoner is no longer in custody and cannot legally seek habeas relief.

    Zupan v. Brown · N.D. Cal. · filed

    The Court finds, therefore, that Heck's requirement that a § 1983 plaintiff must prove that his or her conviction or sentence has been reversed or invalidated does not apply to a § 1983 plaintiff who is no longer in custody and who is unable as a matter of law to bring a habeas petition to challenge his or her conviction or sentence.
    Read the full opinion on CourtListener →

  • The Western District of Louisiana held that Heck's favorable-termination requirement does not apply to a released prisoner.

    White v. Phillips · W.D. La. · filed

    The procedural posture of White’s complaint poses a question of first impression in the Fifth Circuit: Does the “favorable termination” requirement announced in Heck v. Humphrey, 512 U.S. 477, 114 S.Ct. 2364, 129 L.Ed.2d 383 (1994) apply to petitioners such as White who have been released from prison? In light of the Supreme Court’s disposition in the recent case of Spencer v. Kemna, 523 U.S. 1, 118 S.Ct. 978, 140 L.Ed.2d 43 (1998), we hold that it does not. Heck, therefore, does not bar White’s petition, and he may proceed with his case.
    Read the full opinion on CourtListener →

  • The Northern District of Iowa held that Heck's favorable-termination requirement does not apply to a § 1983 plaintiff legally unable to pursue habeas relief.

    Dible v. Scholl · N.D. Iowa · filed

    Therefore, this court concludes that Heck’s favorable termination requirement is not applicable to a § 1983 plaintiff who is unable as a matter of law to bring a habeas petition to challenge a conviction or sentence.
    Read the full opinion on CourtListener →

  • The Fourth Circuit held that a habeas-ineligible former prisoner may pursue a § 1983 claim for past wrongful confinement without satisfying Heck's favorable-termination requirement.

    Wilson v. Johnson · Fourth Circuit · filed

    Because Wilson’s § 1983 claim seeks damages for past confinement, he does not fall squarely within the holdings of Preiser, Wolff, Heck or Spencer.
    Read the full opinion on CourtListener →

  • The Southern District of New York refused to apply Heck to claims that could controvert an expired conviction because the plaintiff had completed his sentence and could no longer use habeas corpus.

    Farmer v. County of Westchester · S.D.N.Y. · filed

    As a threshold matter, the Court notes that Plaintiff’s claims are not barred by the rule set forth in Heck v. Humphrey, 512 U.S. 477 (1994). Despite that Plaintiff’s claims, if successful, could arguably controvert the validity of his 2012 burglary conviction and sentence, there is no danger here that the instant action “would allow Plaintiff to engage in an end-run around the requirements for bringing a habeas corpus petition because he has completed his term of imprisonment.”
    Read the full opinion on CourtListener →

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