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Heck Inapplicable to Halfway House Suit
The United States Court of Appeals for the District of Columbia Circuit
reversed a lower court's dismissal of a prisoner's suit, for failure to
state a claim. The court held that the favorable termination rule of
Heck v. Humphrey, 512 U.S. 477, 488-87 (1994) was inapplicable.
In June 2001, a federal court revoked Milton Taylor's supervised release
and sentenced him to 6 months in a half way house, for intensive
residential drug treatment.
On August 14, 2001, while Taylor was in the halfway house, a detainer was
issued by the United States Marshals service. The next day he was
transferred to the District of Columbia Central Detention Facility (CDF),
where he remained until January 2002.
Taylor attempted to challenge the decision in two federal actions he filed
in October 2001. Both actions, however, were construed as habeas corpus
petitions and dismissed as moot on September 27, 2002, because Taylor had
been released.
He then filed suit for money damages, alleging that his placement at CDF
instead of a halfway house violated valid court orders. Pursuant to 28
U.S.C. 1915(e)(2)(B)(ii), however, the district court Sua Sponte dismissed
the action for failure to state a claim. The court concluded that
Taylor's claim "goes to the fact or duration of his confinement," and was,
therefore, barred under Heck because Taylor had not established prior
invalidation.
The appellate court reversed, concluding Taylor's claim is not subject to
Heck's prior-invalidation requirement. It explained that [i]f Taylor
succeeds in his action, this will demonstrate nothing more than the
unlawfulness of his placement at the CDF...instead of a halfway house.
Success...will in no way imply that any confinement...was invalid or that
the duration of his confinement should have been shorter. Thus, Heck's
concerns regarding collateral attacks on criminal judgments are not in play
here. See: Taylor v. United States Probation Office, 409 F.3d 426 (D.C.
Cir 2005).
reversed a lower court's dismissal of a prisoner's suit, for failure to
state a claim. The court held that the favorable termination rule of
Heck v. Humphrey, 512 U.S. 477, 488-87 (1994) was inapplicable.
In June 2001, a federal court revoked Milton Taylor's supervised release
and sentenced him to 6 months in a half way house, for intensive
residential drug treatment.
On August 14, 2001, while Taylor was in the halfway house, a detainer was
issued by the United States Marshals service. The next day he was
transferred to the District of Columbia Central Detention Facility (CDF),
where he remained until January 2002.
Taylor attempted to challenge the decision in two federal actions he filed
in October 2001. Both actions, however, were construed as habeas corpus
petitions and dismissed as moot on September 27, 2002, because Taylor had
been released.
He then filed suit for money damages, alleging that his placement at CDF
instead of a halfway house violated valid court orders. Pursuant to 28
U.S.C. 1915(e)(2)(B)(ii), however, the district court Sua Sponte dismissed
the action for failure to state a claim. The court concluded that
Taylor's claim "goes to the fact or duration of his confinement," and was,
therefore, barred under Heck because Taylor had not established prior
invalidation.
The appellate court reversed, concluding Taylor's claim is not subject to
Heck's prior-invalidation requirement. It explained that [i]f Taylor
succeeds in his action, this will demonstrate nothing more than the
unlawfulness of his placement at the CDF...instead of a halfway house.
Success...will in no way imply that any confinement...was invalid or that
the duration of his confinement should have been shorter. Thus, Heck's
concerns regarding collateral attacks on criminal judgments are not in play
here. See: Taylor v. United States Probation Office, 409 F.3d 426 (D.C.
Cir 2005).
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