Edwards et al. v. Balisok
Decided on May 19, 1997; 520 US 641


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed:  Prisoners' rights, due process 

B. Legal Question Presented: 

Is a claim for damages and declaratory relief, brought by a state prisoner challenging the validity of the procedures used to deprive him of good-time credits, cognizable under 42 U.S.C. section (§)1983?
II. CASE SUMMARY:

A. Background:

"Respondent, an inmate of a Washington state prison, was found guilty of prison rule infractions and sentenced to..., the loss of 30 days' good time credit he had previously earned toward his release. Alleging that the procedures used in his disciplinary proceeding violated his Fourteenth Amendment due process rights, he filed this suit under 42 U.S.C. § 1983 for a declaration that those procedures were unconstitutional, compensatory and punitive damages for their use, and an injunction to prevent future violations. Although he expressly reserved the right to seek restoration of the lost good time credits in an appropriate forum, he refrained from requesting that relief [because] the sole remedy in federal court for a prisoner seeking such restoration is habeas corpus.

The District Court applied Heck v. Humphrey, 512 U.S. 477, 487, which held that a state prisoner's claim for damages is not cognizable under §1983 if a judgment for him would 'necessarily imply' the invalidity of his conviction or sentence, unless he can demonstrate that the conviction or sentence has previously been invalidated. Although holding that a judgment for respondent would necessarily imply the invalidity of his disciplinary hearing and the resulting sanctions, the court did not dismiss the suit, but stayed it pending filing and resolution of a state court action for restoration of the good time credits. The Ninth Circuit reversed, holding that a claim challenging only the procedures used in a disciplinary hearing is always cognizable under §1983."

On appeal the U.S. Supreme Court reversed and remanded the judgment of the U.S. Court of Appeals for the Ninth Circuit.
B. Counsel of Record:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
C. The Arguments:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Thomas H. Speedy Rice argued the cause for respondent. With him on the brief was George A. Critchlow.

David C. Fathi, John Midgley, Patricia J. Arthur, Don Saunders, Katrin E. Frank, and Steven R. Shapiro filed a brief for the American Civil Liberties Union et al. as amici curiae urging affirmance.

Kathleen D. Mix, Chief Deputy Attorney General of Washington, argued the cause for petitioners. With her on the briefs were Christine O. Gregoire, Attorney General, and Talis Merle Abolins, William Berggren Collins, Mary E. Fairhurst, and Daniel J. Judge, Assistant Attorneys General.

A brief of amici curiae urging reversal was filed for the State of California et al. by Daniel E. Lungren, Attorney General of California, George Williamson, Chief Assistant Attorney General, and Peter J. Siggins, Senior Assistant Attorney General,

Charles F. C. Ruff, Corporation Counsel of the District of Columbia,

and by the Attorneys General for their respective States as follows: Bruce M. Botelho of Alaska, Grant Woods of Arizona, Gale A. Norton of Colorado, Richard Blumenthal of Connecticut, Robert A. Butterworth of Florida, Carla J. Stovall of Kansas, Mike Moore of Mississippi, Joe Mazurek of Montana, Don Stenberg of Nebraska, Frankie Sue Del Papa of Nevada, Dennis C. Vacco of New York, W. A. Drew Edmondson of Oklahoma, Thomas W. Corbett, Jr., of Pennsylvania, Charles Molony Condon of South Carolina, James S. Gilmore III of Virginia, and James E. Doyle of Wisconsin.





IV. THE SUPREME COURT'S DECISION:

"Respondent's claim for declaratory relief and money damages is not cognizable under §1983. The principle relied on by the Ninth Circuit--that a claim seeking damages only for using the wrong procedures, not for reaching the wrong result, is always cognizable under §1983--is incorrect, since it disregards the possibility..., that the nature of the challenge to the procedures could be such as necessarily to imply the invalidity of the judgment. If established, respondent's allegations of deceit and bias by the hearing officer at his disciplinary proceeding would necessarily imply the invalidity of the deprivation of his good time credits...

Although a prayer for prospective injunctive relief ordinarily will not 'necessarily imply' the invalidity of a previous loss of good time credits, and so may properly be brought under §1983, respondent's claim for such relief must be remanded because it was not considered by either lower court, and its validity was neither briefed nor argued here.

The District Court erred in staying this §1983 action. [A]bsent some other bar to the suit, a claim either is cognizable under §1983 and should immediately go forward, or is not cognizable and should be dismissed."

The U.S Supreme Court reversed and remanded the judgment of the U.S. Court of Appeals for the Ninth Circuit.

Justice Vote: 0 Pro vs. 9 Con

  • Scalia, A. Con (Wrote majority opinion)
  • Rehnquist, W. Con (Joined majority opinion)
  • O'Connor, S. Con (Joined majority opinion)
  • Breyer, S. Con (Joined majority opinion)
  • Souter, D. Con (Joined majority opinion)
  • Kennedy, A. Con (Joined majority opinion)
  • Thomas, C. Con (Joined majority opinion)
  • Stevens, J. Con (Joined majority opinion)
  • Ginsburg, R. Con (Wrote concurring opinion)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU, as amicus curiae, urged affirmance of the U.S. Court of Appeals for the Ninth Circuit judgment; the Supreme Court reversed and remanded in a 9-0 vote, giving the ACLU an apparent loss.