Gabriel Olivier v. City of Brandon, Mississippi, et al.
1. This case presents an important, recurring question that has divided circuits regarding the reach of this Court's decision in Heck v. Humphrey, 512 U.S. 477 (1994). In Heck, this Court held that a prisoner cannot bring a claim under 42 U.S.C. § 1983 that, if successful, would "necessarily imply the invalidity of his conviction or sentence" unless "the conviction or sentence [is] invalidated." Id. at 487, 490. Instead, a prisoner may bring such claims only in a habeas proceeding. Since Heck, the circuits have split over whether § 1983 plaintiffs may pursue prospective injunctive relief against future enforcement of allegedly unconstitutional laws. The Ninth and Tenth Circuits have held that Heck doesn't bar such suits. Martin v. City of Boise, 920 F.3d 584, 615 (9th Cir. 2019), abrogated on other grounds by City of Grants Pass v. Johnson, 603 U.S. 520 (2024); Lawrence v. McCall, 238 F. App'x 393, 395-96 (10th Cir. 2007). But in the decision below, the Fifth Circuit relied on circuit precedent holding that Heck bars that relief. See App., infra, 9a; Clarke v. Stalder, 154 F.3d 186, 190 (5th Cir. 1998) (en banc).
2. The Fifth Circuit's decision warrants this Court's review. It openly splits with the decisions of other courts of appeals and conflicts with this Court's precedent.
Whether Heck v. Humphrey precludes a § 1983 plaintiff from seeking prospective injunctive relief challenging a law under which they were previously convicted without invalidating that conviction