Does the favorable termination rule or Heck bar apply to a state prisoner's good-time credit action?

MultiRegion, United States of America

The following excerpt is from Jacques v. Lopez, Case No. 1:16-cv-01289-DAD-SAB (PC) (E.D. Cal. 2019):

"a state prisoner's 1983 action is barred (absent prior invalidation) - no matter the relief sought (damages or equitable relief), no matter the target of the prisoner's suit (state conduct leading to conviction or internal prison proceedings) - if success in that action would necessarily demonstrate the invalidity of confinement or its duration." Id. at 81-82. In the prison disciplinary context, the favorable termination rule or Heck bar applies if the "defect complained of by [Plaintiff] would, if established, necessarily imply the invalidity of the deprivation of his good-time credits[,]" Edwards v. Balisok, 520 U.S. 641, 646 (1997), and if the restoration of those credits "necessarily" would "affect the duration of time to be served[.]" Muhammad v. Close, 540 U.S. 749, 754 (2004) (per curiam).

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