The following excerpt is from Brodheim v. Dickinson, No. 2:06 cv 02326 LKK GGH P (E.D. Cal. 2013):
Butterfield v. Bail, 120 F.3d 1023-24 (9th Cir. 1997) (claim challenging use of allegedly false material in a prisoner's file which was used to deny parole necessarily implicates the continuation of confinement, and is only properly (initially) reviewed in habeas corpus).
Neal v. Shimoda, 131 F.3d 818, 824 (9th Cir. 1997): expungement of sex offender labeling, although giving petitioner a "ticket" to get parole board consideration, is properly brought in civil rights because it will in no way guarantee parole.
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