[Download] "Muhammad v. Close" by Supreme Court of the United States * eBook PDF Kindle ePub Free
eBook details
- Title: Muhammad v. Close
- Author : Supreme Court of the United States
- Release Date : January 25, 2004
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 64 KB
Description
Federal law opens two main avenues to relief on complaints related to imprisonment: a petition for habeas corpus, 28 U. S. C. §2254, and a complaint under the Civil Rights Act of 1871, Rev. Stat. §1979, as amended, 42 U. S. C. §1983. Challenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus, Preiser v. Rodriguez, 411 U. S. 475, 500 (1973); requests for relief turning on circumstances of confinement may be presented in a §1983 action. Some cases are hybrids, with a prisoner seeking relief unavailable in habeas, notably damages, but on allegations that not only support a claim for recompense, but imply the invalidity either of an underlying conviction or of a particular ground for denying release short of serving the maximum term of confinement. In Heck v. Humphrey, 512 U. S. 477 (1994), we held that where success in a prisoners §1983 damages action would implicitly question the validity of conviction or duration of sentence, the litigant must first achieve favorable termination of his available state, or federal habeas, opportunities to challenge the underlying conviction or sentence. Accordingly, in Edwards v. Balisok, 520 U. S. 641 (1997), we applied Heck in the circumstances of a §1983 action claiming damages and equitable relief for a procedural defect in a prisons administrative process, where the administrative action taken against the plaintiff could affect credits toward release based on good-time served. In each instance, conditioning the right to bring a §1983 action on a favorable result in state litigation or federal habeas served the practical objective of preserving limitations on the availability of habeas remedies. Federal petitions for habeas corpus may be granted only after other avenues of relief have been exhausted. 28 U. S. C. §2254(b)(1)(A). See Rose v. Lundy, 455 U. S. 509 (1982). Prisoners suing under §1983, in contrast, generally face a substantially lower gate, even with the requirement of the Prison Litigation Reform Act of 1995 that administrative opportunities be exhausted first. 42 U. S. C. §1997e(a).