Case Citator › Figueroa v. Rivera-Garcia

Figueroa v. Rivera-Garcia

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

Declined by some courts
Court
First Circuit
Citation
147 F.3d 77
Decided
Confirmed treatments
3
Flagged citations read
31 of 31
Citing cases (total)
31
Treatment dates
2003–2008
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. Figueroa v. Rivera-Garcia has been declined by other federal appeals courts: all 31 flagged citations have been read, and the confirmed treatments are listed below. The Sixth and Fourth Circuits allowed civil rights claims to proceed when habeas relief was unavailable, contrary to Figueroa’s reading of Heck v. Humphrey.
More on how this was screened

A Massachusetts district court also criticized Figueroa’s reasoning while recognizing that the First Circuit’s decision bound it.

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.

31 later cases cite Figueroa v. Rivera-Garcia; 31 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. 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 Figueroa v. Rivera-Garcia?

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

Declined to follow

  • The Sixth Circuit rejected Figueroa’s rule that a plaintiff without a habeas remedy must first invalidate the conviction before bringing a civil rights claim.

    Powers v. Hamilton County Public Defender Commission · Sixth Circuit · filed

    In Figueroa v. Rivera, for example, the appellants brought a § 1983 action on behalf of a convicted murderer, Rios, who had died in prison. ... The First Circuit acknowledged that Rios “was attempting to impugn his conviction when death intervened,” but it nonetheless determined that Heck barred the appellants’ § 1983 suit because Rios’s conviction had not been set aside in a prior proceeding. ... We disagree with the reasoning of our sister circuits who have decreed themselves bound by Heck to the exclusion of Justice Souter’s comments in his Heck and Spencer concurrences.
    Read the full opinion on CourtListener →

  • The Fourth Circuit identified Figueroa among courts applying Heck to people without a habeas remedy, then adopted the opposite rule for such claims.

    Wilson v. Johnson · Fourth Circuit · filed

    Four circuits regard the five justice plurality in Spencer as dicta, and continue to interpret Heck as barring individuals from filing virtually all § 1983 claims unless the favorable termination requirement is met.6 ... We believe that the reasoning employed by the plurality in Spencer must prevail in a case, like Wil*268son’s, where an individual would be left without any access to federal court if his § 1983 claim was barred. ... See e.g., Figueroa v. Rivera, 147 F.3d 77, 80 (1st Cir.1998)
    Read the full opinion on CourtListener →

Criticized

  • The District of Massachusetts called Figueroa’s reasoning puzzling while acknowledging that its holding bound the court.

    Limone v. United States · District of Massachusetts · filed

    While I obviously am bound by the First Circuit’s holding in Figueroa, the court’s reasoning is puzzling.
    Read the full opinion on CourtListener →

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