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Edwards v. Balisok: A Partial Victory for Prisoners

by David C. Fathi

On May 19, 1997, the United States Supreme Court decided Edwards v. Balisok, 520 U.S. 117 S.Ct. 1584 (1997). Although the Court reversed a favorable decision by the U.S. Court of Appeals for the Ninth Circuit, it also reaffirmed the ability of prisoners to challenge unfair prison disciplinary proceedings under 42 U.S.C. §1983.


THE ISSUE

The issue in Balisok was whether a claim for damages and declaratory relief by a state prisoner challenging prison disciplinary procedures can be brought under §1983, or whether the only federal vehicle for such a challenge is a habeas corpus proceeding. The distinction is important, because damages and injunctions are not available in habeas proceedings, and federal habeas, unlike §1983, requires a state prisoner to first exhaust his or her state remedies.

BACKGROUND

Jerry B. Balisok, a Washington state prisoner, was found guilty in a prison disciplinary hearing, and was sentenced to 10 days in isolation, 20 days in segregation, and loss of 30 days' good-time credit. He filed suit in federal district court under §1983, alleging that the disciplinary proceedings violated his due process rights under the Fourteenth Amendment. Specifically, he alleged that the hearing officer concealed exculpatory witness statements, refused to ask specified questions of requested witnesses, and in general "intentionally denied" him the right to present evidence in his defense. Balisok's complaint sought a declaration that these procedures violated due process, compensatory and punitive damages for use of the unconstitutional procedures, an injunction to prevent future violations, and any other relief the court deemed just and equitable. He did not seek restoration of his good-time credits in this §1983 suit, since the Supreme Court has made clear that the sole federal remedy for a prisoner seeking restoration of good-time credits is a writ of habeas corpus. Preiser v. Rodriguez, 411 U.S. 475, 500 (1973).

The district court applied the Supreme Court's opinion in Heck v. Humphrey, 512 U.S. 477 (1994) [PLN Sept. 1994], to Balisok's claim. In Heck, the Supreme Court had held that a state prisoner could not bring a claim for damages under §1983 for unconstitutional procedures used at his criminal trial, if "a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence," unless the prisoner could show that the conviction or sentence had previously been invalidated. The district court held that, similarly, a judgment in Balisok's favor would necessarily imply the invalidity of his disciplinary hearing and the resulting loss of good time. It therefore stayed Balisok's lawsuit.

Balisok appealed, and in a brief unpublished opinion, the Ninth Circuit reversed, and held that Balisok's suit could go forward. The Ninth Circuit relied on its prior decision in Gotcher v. Wood, 66 F.3d 1097 (9th Cir. 1995), which had held that a prisoner's challenge to the procedures by which he was denied good-time credits (as distinguished from a challenge to the denial itself) did not call into question the lawfulness of his continuing confinement, and thus was not barred by Heck.

THE SUPREME COURT DECISION

The Supreme Court reversed in a unanimous and surprisingly brief opinion by Justice Scalia. It held that the Ninth Circuit had been wrong to hold in Gotcher that a claim challenging only the procedures employed in a disciplinary hearing is never barred by Heck. Rather, the Court said, some procedural defects are so fundamental that they necessarily imply the invalidity of any resulting loss of good-time credits. A claim alleging such defects is barred by Heck, and cannot be brought under §1983. The Court held that Balisok's claim -- that the hearing officer was biased against him, lied to him, and "intentionally denied" him the opportunity to put on any defense -- alleged such a fundamental defect, and thus was barred under Heck.

Although Balisok's claim for damages and declaratory relief was barred, other claims survived. Balisok had also sought an injunction against the prison's alleged practice of failing to date-stamp witness statements in cases involving "jail house attorneys" like himself. The Court held that "[o]rdinarily, a prayer for [injunctive] relief will not 'necessarily imply' the invalidity of a previous loss of good-time credits, and so may properly be brought under §1983." This is important because a habeas corpus proceeding provides no means equivalent to an injunction for a court to order prison officials to stop an ongoing course of illegal conduct.

In addition, a brief concurring opinion by Justices Ginsburg, Souter, and Breyer pointed out that Balisok alleged additional defects in his disciplinary proceeding, such as the hearing officer's failure to specify the evidence that supported the finding of guilt, as required by Wolff v. McDonnell, 418 U.S. 539, 565-65 (1974). "A defect of this order, unlike the principal 'deceit and bias' procedural defect Balisok alleged, ... would not necessarily imply the invalidity of the deprivation of his good-time credits, and therefore is immediately cognizable under §1983." Nothing in the majority opinion takes issue with this statement.

The Court's opinion contains other useful language. In explaining why Balisok's allegations, if true, would "necessarily imply" the invalidity of his loss of good time, the Court said, "[t]he due process requirements for a prison disciplinary hearing are in many respects less demanding than those for criminal prosecution, but they are not so lax as to let stand the decision of a biased hearing officer who dishonestly suppresses evidence of innocence." This is so, the Court said, even if there is overwhelming evidence of the prisoner's guilt. This passage will be useful in future challenges to disciplinary proceedings based on bias or suppression of evidence by the hearing officer.

The majority opinion also reaffirmed that, in cases that are not barred by Heck, a prisoner is entitled to at least nominal damages under §1983 if he or she establishes that unconstitutional procedures were employed in a prison disciplinary proceeding. See Carey v. Piphus, 435 U.S. 247, 266-67 (1978).

Finally, the Court also reaffirmed that §1983 contains no requirement that a plaintiff exhaust state remedies before proceeding to federal court. Although this was clearly established in Patsy v. Board of Regents, 457 U.S. 496 (1982), the State of Washington in Balisok had urged that prisoners be required to exhaust state remedies in all challenges to disciplinary proceedings involving loss of good time. By holding that §1983 remains available for some such challenges, and re-emphasizing that §1983 contains no exhaustion requirement, the Court rejected this position. Readers should note, however, that the Prison Litigation Reform Act does impose some exhaustion requirements on §1983 actions by prisoners. See 42 U.S.C. §1997e(a). These requirements were not at issue in Balisok.

GOTCHER v. WOOD VACATED

The State of Washington had also petitioned for certiorari in Gotcher v. Wood. On May 27, 1997, the Court granted certiorari, vacated the decision of the Ninth Circuit, and remanded the case to that court for consideration in light of Balisok. Therefore Gotcher, 66 F.3d 1097 (9th Cir. 1995), can no longer be cited as binding authority. This applies not only to Gotcher's discussion of the Heck issue, but also its discussion of whether, in light of Sandin v. Conner, 115 S. Ct. 2293 (1995), Washington state prisoners have a liberty interest in the accumulation of good-time credits and in remaining free from disciplinary segregation. The Ninth Circuit will probably issue a new decision in Gotcher later this year, and may address the Sandin issue again.


IMPLICATIONS
FOR FUTURE LITIGATION

Balisok provides some guidance on which claims regarding prison disciplinary proceedings can be brought under §1983. On the one hand, it is clear that a claim seeking only prospective injunctive relief (that is, an order to prison officials to cease an ongoing course of illegal conduct) can be brought under §1983. With respect to claims seeking damages and/or declaratory relief, the issue will be whether success on the claim would "necessarily invalidate" the loss of good-time credits that resulted from the challenged hearing. Balisok makes clear that a claim of actual bias on the part of the hearing officer, or that the prisoner was completely denied the opportunity to put on a defense, would if successful "necessarily invalidate" any resulting loss of good time, and thus cannot be brought under §1983. By contrast, the concurring opinion says (and the majority does not dispute) that a claim that the hearing officer failed to provide a statement of the evidence relied upon can be brought under §1983, because success on this claim would not necessarily invalidate a loss of good-time credits.

The situation is less clear with regard to other procedural defects. The improper admission of evidence probably would not "necessarily invalidate" the results of a disciplinary hearing, as long as there is some untainted evidence to support the finding of guilt. See Superintendent, Mass. Correctional Inst. v. Hill, 472 U.S. 445 (1985). The same is probably true of erroneous exclusion of evidence offered by the prisoner, as long as the prisoner was not completely prevented from putting on a defense, as Balisok alleged he was. Arizona v. Fulminante, 499 U.S. 279, 306-07 (1991), sets forth a list of trial errors that the Supreme Court has held may be harmless in some circumstances. Defects in disciplinary proceedings that are analogous to these errors will probably be held not to "necessarily invalidate" the results of the proceeding. By contrast, it seems likely that the more serious the procedural defect alleged by the prisoner, the more likely a court will say that success on the claim would "necessarily invalidate" the result of the disciplinary proceeding, and that therefore the challenge cannot be brought under §1983.

[David C. Fathi is a staff attorney at the Institutions Project of Columbia Legal Services in Seattle. He is co-counsel in Gotcher v. Wood, and was the co-author of an amicus curiae brief in support of Mr. Balisok in the Supreme Court.]

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Related legal case

Edwards v. Balisok

Edwards v. Balisok, No. 95-1352 (U.S. 05/19/1997)

[1] SUPREME COURT OF THE UNITED STATES


[2] No. 95-1352


[3] 1997


[4] May 19, 1997


[5] GARY EDWARDS AND TANA WOOD, PETITIONERS

v.

JERRY B. BALISOK


[6] SYLLABUS BY THE COURT


[7] Certiorari to the United States Court of Appeals for the Ninth Circuit


[8] No. 95-1352


[9] Argued November 13, 1996


[10] Decided May 19, 1997


[11] Respondent, an inmate of a Washington state prison, was found guilty of prison rule infractions and sentenced to, inter alia, 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. Section(s) 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 in light of Preiser v. Rodriguez, 411 U. S. 475, 500, under which 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 Section(s) 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 Section(s) 1983.


[12] Held:


[13] 1. Respondent's claim for declaratory relief and money damages is not cognizable under Section(s) 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 Section(s) 1983-is incorrect, since it disregards the possibility, clearly envisioned by Heck, supra, at 482-483, 486-487, and n. 6, 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. Cf., e.g., Tumey v. Ohio, 273 U. S. 510, 535. His contrary contention, which is based on Washington's "some or any evidence" standard, is rejected. Pp. 2-7.


[14] 2. 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 Section(s) 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. P. 7.


[15] 3. The District Court erred in staying this Section(s) 1983 action. That court was mistaken in its view that once respondent had exhausted his state remedies, the action could proceed. Section 1983 contains no judicially imposed exhaustion requirement, Heck, supra, at 481, 483; absent some other bar to the suit, a claim either is cognizable under Section(s) 1983 and should immediately go forward, or is not cognizable and should be dismissed. Pp. 7. 70 F. 3d 1277, reversed and remanded.


[16] Scalia, J., delivered the opinion for a unanimous Court. Ginsburg, J., filed a concurring opinion, in which Souter and Breyer, JJ., joined.


[17] Justice Scalia


[18] On Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit


[19] In Heck v. Humphrey, 512 U. S. 477, 487 (1994), this Court held that a state prisoner's claim for damages is not cognizable under 42 U. S. C. Section(s) 1983 if "a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence," unless the prisoner can demonstrate that the conviction or sentence has previously been invalidated. This case presents the question whether 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 is cognizable under Section(s) 1983.


[20] Respondent Jerry Balisok is an inmate at the Washington State Penitentiary in Walla Walla. On August 16, 1993, he was charged with, and at a hearing on September 2 was found guilty of, four prison infractions. He was sentenced to 10 days in isolation, 20 days in segregation, and deprivation of 30 days' good-time credit he had previously earned toward his release. His appeal within the prison's appeal system was rejected for failure to comply with the applicable procedural requirements.


[21] On January 26, 1994, respondent filed the present Section(s) 1983 action alleging that the procedures used in his disciplinary proceeding violated his Fourteenth Amendment due process rights. His amended complaint requested a declaration that the procedures employed by state officials violated due process, compensatory and punitive damages for use of the unconstitutional procedures, an injunction to prevent future violations, and any other relief the court deems just and equitable. Taking account of our opinion in Preiser v. Rodriguez, 411 U. S. 475, 500 (1973), which held that the sole remedy in federal court for a prisoner seeking restoration of good-time credits is a writ of habeas corpus, Balisok's amended complaint did not request restoration of the lost credits. (As the District Court noted, however, he expressly reserved the right to seek that relief in an appropriate forum. App. to Pet. for Cert. F-4.)


[22] The District Court, applying our opinion in Heck, held that a judgment in Balisok's favor "would necessarily imply the invalidity of the disciplinary hearing and the resulting sanctions." App. to Pet. for Cert. F-14. Rather than grant petitioners' motion to dismiss, however, the District Court stayed this action pending filing and resolution of a state-court action for restoration of the good-time credits. It authorized an immediate appeal of its ruling pursuant to 28 U. S. C. Section(s) 1292(b), and the Court of Appeals for the Ninth Circuit reversed, holding that a claim challenging only the procedures employed in a disciplinary hearing is always cognizable under Section(s) 1983. App. to Pet. for Cert. A-2. We granted certiorari. 517 U. S. ___ (1996).


[23] The violations of due process alleged by respondent are similar to those alleged by the plaintiff in Heck. There, the allegations were that the state officials had conducted an arbitrary investigation, had knowingly destroyed exculpatory evidence, and had caused an illegal voice identification procedure to be used at the plaintiff's criminal trial. 512 U. S., at 479. Here, respondent principally alleged that petitioner Edwards, who was the hearing officer at his disciplinary proceeding, concealed exculpatory witness statements and refused to ask specified questions of requested witnesses, App. to Pet. for Cert. I-3 to I-7, which prevented respondent from introducing extant exculpatory material and "intentionally denied" him the right to present evidence in his defense, Brief for Respondent 3. (Respondent also alleged that Edwards failed to provide a statement of the facts supporting the guilty finding against him, App. to Pet. for Cert. I-6 to I-7, and that petitioner Wood erroneously rejected his appeal as exceeding the page limitation, id., at I-7 to I-8.)


[24] There is, however, this critical difference from Heck: Respondent, in his amended complaint, limited his request to damages for depriving him of good-time credits without due process, not for depriving him of good-time credits undeservedly as a substantive matter. *fn* That is to say, his claim posited that the procedures were wrong, but not necessarily that the result was. The distinction between these two sorts of claims is clearly established in our case law, as is the plaintiff's entitlement to recover at least nominal damages under Section(s) 1983 if he proves the former one without also proving the latter one. See Carey v. Piphus, 435 U. S. 247, 266-267 (1978). The Court of Appeals was of the view that this difference from Heck was dispositive, following Circuit precedent to the effect that a claim challenging only the procedures employed in a disciplinary hearing is always cognizable under Section(s) 1983. See App. to Pet. for Cert. A-2, citing Gotcher v. Wood, 66 F. 3d 1097, 1099 (CA9 1995), cert. pending, No. 95-1385.


[25] That principle is incorrect, since it disregards the possibility, clearly envisioned by Heck, that the nature of the challenge to the procedures could be such as necessarily to imply the invalidity of the judgment. This possibility is alluded to in the very passage from Heck relied upon by the Court of Appeals, a passage that distinguished the earlier case of Wolff v. McDonnell, 418 U. S. 539 (1974), as follows:


[26] "In light of the earlier language characterizing the claim as one of `damages for the deprivation of civil rights,' rather than damages for the deprivation of good-time credits, we think this passage recognized a Section(s) 1983 claim for using the wrong procedures, not for reaching the wrong result (i.e., denying good-time credits). Nor is there any indication in the opinion, or any reason to believe, that using the wrong procedures necessarily vitiated the denial of good-time credits. Thus, the claim at issue in Wolff did not call into question the lawfulness of the plaintiff's continuing confinement." Heck, supra, at 482-483 (emphasis added).


[27] The same point was apparent in Heck's summary of its holding:


[28] "We hold that, in order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid,6 a Section(s) 1983 plaintiff must prove that the conviction or sentence has been [overturned]." 512 U. S., at 486-487 (emphasis added).


[29] The footnote appended to the above-italicized clause gave a concrete example of "a Section(s) 1983 action that does not seek damages directly attributable to conviction or confinement but whose successful prosecution would necessarily imply that the plaintiff's criminal conviction was wrongful." Id., at 486, n. 6. The Court of Appeals was thus incorrect in asserting that a claim seeking damages only "for using the wrong procedure, not for reaching the wrong result," Gotcher, supra, at 1099, would never be subject to the limitation announced in Heck.


[30] The principal procedural defect complained of by respondent would, if established, necessarily imply the invalidity of the deprivation of his good-time credits. His claim is, first of all, that he was completely denied the opportunity to put on a defense through specifically identified witnesses who possessed exculpatory evidence. It appears that all witness testimony in his defense was excluded. See App. to Pet. for Cert. F-2 (District Court opinion) ("At the infraction hearing . . ., [respondent] asked that the witness statements be read into the record. According to [respondent], Edwards replied that no witness statements had been submitted on his behalf"). This is an obvious procedural defect, and state and federal courts have reinstated good-time credits (absent a new hearing) when it is established. See, e.g., Kingsley v. Bureau of Prisons, 937 F. 2d 26, 27, 31 (CA2 1991); Dumas v. State, 654 So. 2d 48, 49 (Ala. Crim. App. 1994); Mahers v. State, 437 N. W. 2d 565, 568-569 (Iowa 1989); In re Contras, 199 App. Div. 2d 601, 602, 604 N. Y. S. 2d 651, 652 (1993). Cf. In re Reismiller, 101 Wash. 2d 291, 293-297, 678 P. 2d 323, 325, 326 (1984); In re Burton, 80 Wash. App. 573, 585, 910 P. 2d 1295, 1304 (1996). Respondent's claim, however, goes even further, asserting that the cause of the exclusion of the exculpatory evidence was the deceit and bias of the hearing officer himself. He contends that the hearing officer lied about the nonexistence of witness statements, see App. to Pet. for Cert. I-4, I-6, I-7; Brief for Respondent 2-3; App. 4, and thus "intentionally denied" him the right to present the extant exculpatory evidence, Brief for Respondent 3. A criminal defendant tried by a partial judge is entitled to have his conviction set aside, no matter how strong the evidence against him. Tumey v. Ohio, 273 U. S. 510, 535 (1927); Arizona v. Fulminante, 499 U. S. 279, 308 (1991). The due process requirements for a prison disciplinary hearing are in many respects less demanding than those for criminal prosecution, but they are not so lax as to let stand the decision of a biased hearing officer who dishonestly suppresses evidence of innocence. Cf. Wolff, supra, at 570-571.


[31] Respondent contends that a judgment in his favor would not imply the invalidity of the loss of his good-time credits because Washington courts follow a "some or any evidence" standard, under which, "if there is any evidence in the record to support the prison hearing determination, then the court will not undertake an entire review of the record and will uphold prison hearing results." Brief for Respondent 7, citing Superintendent, Mass. Correctional Institution at Walpole v. Hill, 472 U. S. 445 (1985); Brief for Respondent 21 (citing Washington state cases). Here, respondent points out, the record contains ample evidence to support the judgment under this standard. That may be true, but when the basis for attacking the judgment is not insufficiency of the evidence, it is irrelevant. As the Washington Supreme Court has explained: "The evidentiary requirements of due process are satisfied if there is `some evidence' in the record to support a prison disciplinary decision revoking good time credits." In re Johnston, 109 Wash. 2d 493, 497, 745 P. 2d 864, 867 (1987) (emphasis added). Similarly, our discussion in Hill in no way abrogated the due process requirements enunciated in Wolff, but simply held that in addition to those requirements, revocation of good-time credits does not comport with " `the minimum requirements of procedural due process,' " unless the findings are "supported by some evidence in the record." 472 U. S., at 454 (quoting Wolff, supra, at 558).


[32] We conclude, therefore, that respondent's claim for declaratory relief and money damages, based on allegations of deceit and bias on the part of the decisionmaker that necessarily imply the invalidity of the punishment imposed, is not cognizable under Section(s) 1983. Respondent also requests, however, prospective injunctive relief. His amended complaint alleges that prison officials routinely fail to date-stamp witness statements that are made in cases involving "jail house attorney[s]" like himself, in order to weaken any due-process challenge for failure to call witnesses. App. to Pet. for Cert. I-4. He requests an injunction requiring prison officials to date-stamp witness statements at the time they are received. Id., at I-10. Ordinarily, a prayer for such prospective relief will not "necessarily imply" the invalidity of a previous loss of good-time credits, and so may properly be brought under Section(s) 1983. To prevail, of course, respondent must establish standing, see Lewis v. Casey, 518 U. S.___, ___ (1996) (slip op., at 7-10), and meet the usual requirements for injunctive relief, see, e.g., O'Shea v. Littleton, 414 U. S. 488, 499, 502 (1974). Neither the Ninth Circuit nor the District Court considered this injunctive claim, and its validity was neither briefed nor argued here. We leave this issue for consideration by the lower courts on remand.


[33] Since we are remanding, we must add a word concerning the District Court's decision to stay this Section(s) 1983 action while respondent sought restoration of his good-time credits, rather than dismiss it. The District Court was of the view that once respondent had exhausted his state remedies, the Section(s) 1983 action could proceed. App. to Pet. for Cert. F-14. This was error. We reemphasize that Section(s) 1983 contains no judicially imposed exhaustion requirement, Heck, 512 U. S., at 481, 483; absent some other bar to the suit, a claim either is cognizable under Section(s) 1983 and should immediately go forward, or is not cognizable and should be dismissed.


[34] The judgment of the Ninth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.


[35] It is so ordered.


[36] Justice Ginsburg, with whom Justice Souter and Justice Breyer join, concurring.


[37] I agree that Balisok's claim is not cognizable under 42 U. S. C. Section(s) 1983 to the extent that it is "based on allegations of deceit and bias on the part of the decisionmaker," ante, at 6; those allegations, as the Court explains, "necessarily imply the invalidity of the punishment imposed," ante, at 7; see ante, at 5-6. Balisok alleged other procedural defects, however, including the failure of prison official Edwards "to specify what facts and evidence supported the finding of guilt." App. to Pet. for Cert. F-3 (District Court order); see Wolff v. McDonnell, 418 U. S. 539, 564-565 (1974) (inmate subjected to discipline is entitled to a written statement of reasons and evidence relied on). A defect of this order, unlike the principal "deceit and bias" procedural defect Balisok alleged, see ante, at 5, would not necessarily imply the invalidity of the deprivation of his good-time credits, and therefore is immediately cognizable under Section(s) 1983. On this understanding, I join the Court's opinion.



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Opinion Footnotes

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[38] *fn* The amended complaint could be considered ambiguous on the point, but this was the Court of Appeals' interpretation, which has been accepted by petitioners. Id., at 5.

 

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