Heck v. Humphrey

Roy Heck (plaintiff), serving 15 years for voluntary manslaughter under an Indiana conviction, filed a §1983 damages suit in federal court while his state appeal was still pending, alleging that state prosecutors and a police investigator (defendants) had conducted an illegal investigation, destroyed evidence, and used an improper voice-identification procedure at his trial. He sought only compensatory and punitive damages, not release from custody. The district court dismissed the suit without prejudice because the claims effectively challenged the validity of his confinement, and while his appeal of that dismissal was pending, the Indiana Supreme Court upheld his conviction and his separate federal habeas petition was also denied and affirmed on appeal. The court of appeals then denied his §1983 appeal too, adopting the district court's reasoning, and the Supreme Court granted certiorari.