Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against the police department and three of its former detectives for damages under 42 U.S.C. 1983, alleging that the police and prosecution withheld evidence in violation of Brady v. Maryland during plaintiff's 1982 murder trial. The district court dismissed the case under Heck v. Humphrey. The court affirmed the judgment, concluding that this case involves section 1983 claims that are predicated on alleged Brady violations which would, if proven, necessarily imply the invalidity of plaintiff's convictions. Those convictions have not been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal, or called into question by a federal court's issuance of a writ of habeas corpus. Therefore, under Heck, they may not be collaterally attacked through section 1983 now. The court concluded that the fact that plaintiff is no longer in custody does not change this result. Finally, plaintiff has identified no impediment to habeas access warranting an expansion of the Heck exception. View "Griffin v. Baltimore Police Dept." on Justia Law