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Stephenson v. Reno

United States Court of Appeals, Fifth Circuit
Aug 8, 1994
28 F.3d 26 (5th Cir. 1994)

Summary

holding that a federal prisoner's Bivens action is subject to the rule enunciated in Heck

Summary of this case from Cheek v. United States

Opinion

No. 94-30080. Conference Calendar.

August 8, 1994.

Obadiah Stephenson, Sr., pro se.

Appeal from the United States District Court for the Eastern District of Louisiana.

Before POLITZ, Chief Judge, and JOLLY and DAVIS, Circuit Judges.


Obadiah Stephenson, Sr., a federal prisoner at the Federal Correctional Institution at Texarkana, Texas, filed the instant civil rights action under 28 U.S.C. §§ 1331, 1343(3), and 42 U.S.C. § 1985. The complaint named seventeen federal defendants, ranging from Attorney General Janet Reno to the assistant federal public defender who represented Stephenson in the criminal proceeding which forms the basis for this lawsuit. His complaint asserts a myriad of alleged violations of his civil rights and requests over $100 million in damages, all resulting from the investigation, conviction, and sentencing of Stephenson in federal court for conspiracy to possess with intent to distribute cocaine in violation of 21 U.S.C. §§ 841(a)(1), 846.

Because it alleges civil rights violations by federal defendants, however, the action is construed as one brought pursuant to Bivens v. Six Unknown Named Agents, 403 U.S. 388, 91 S.Ct. 1999, 29 L.Ed.2d 619 (1971).

The district court noted that Stephenson's complaint constituted an attack on the fact or length of his confinement and, as such, concluded that Stephenson's exclusive initial remedy for such a challenge was a collateral attack on his conviction under 28 U.S.C. § 2255. The court held that, to the extent that Stephenson's complaint raised any civil rights claims, it would be held in abeyance, reserving to Stephenson the right to move to reopen the case within the six months following the exhaustion of his postconviction remedies. Stephenson now appeals from that order.

An order holding a plaintiff's civil rights complaint in abeyance pending the exhaustion of state remedies is appealable under the collateral order doctrine. See Johnson v. State of Texas, 878 F.2d 904, 905-06 (5th Cir. 1989).

The law on exhaustion of habeas corpus remedies has changed since the district court ruled. In Heck v. Humphrey, ___ U.S. ___, 114 S.Ct. 2364, 129 L.Ed.2d 383 (1994), the Supreme Court held that, in order to recover damages for an allegedly unconstitutional conviction, or for "harm caused by actions whose unlawfulness would render a conviction or sentence invalid," a prisoner must show that the conviction or sentence has been "reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court's issuance of a writ of habeas corpus." ___ U.S. at ___, 114 S.Ct. at 2372. The Court analogized such a claim to the tort of malicious prosecution, one element of which is "the termination of the prior criminal proceeding in favor of the accused." Id. at ___, 114 S.Ct. at 2371.

Heck was a civil rights suit brought by a state prisoner, whereas Stephenson is a federal prisoner whose habeas remedies lie, not under 28 U.S.C. § 2254, but 28 U.S.C. § 2255. In Spina v. Aaron, 821 F.2d 1126, 1127-29 (5th Cir. 1987), however, we held that, for purposes of a civil rights action implicating the validity of a conviction, there should be no distinction between state and federal prisoners and that the analysis of a federal prisoner's Bivens-type action which implicated his conviction "should parallel the analysis used to evaluate state prisoners' § 1983 claims." Therefore, if the district court was correct in determining that Stephenson's claims implicated his conviction, Heck applies.

Stephenson's civil rights action does constitute a challenge to the fact or length of his confinement. In particular, his action alleges that: law enforcement officials violated his constitutional rights when they were investigating him; he was held without an indictment; his court-appointed counsel rendered ineffective assistance; the district court illegally indicted and sentenced him; and all of the named defendants conspired to violate his constitutional rights, obstruct justice, commit mail fraud, common-law fraud, violate RICO, and engage in "out law [sic] conduct."

In fact, Stephenson concedes that the basis of his action is a challenge to the "constitutional validity of his Federal Court conviction and confinement." The plain language of Stephenson's brief and complaint establishes that his action falls directly within the strictures we enunciated in Spina.

The law of this Circuit that such civil rights actions be dismissed without prejudice and the running of the applicable statute of limitations tolled while the plaintiff was exhausting state remedies, see Rodriguez v. Holmes, 963 F.2d 799, 804-05 (5th Cir. 1992), is no longer applicable. Under Heck, "the statute of limitations poses no difficulty while the state challenges are being pursued, since the § 1983 claim has not yet arisen." Heck, ___ U.S. at ___, 114 S.Ct. at 2374. Therefore, because Heck dictates that a cause of action seeking damages under § 1983 for an unconstitutional conviction or sentence does not accrue until the conviction or sentence has been invalidated, see id., there is no longer a need to dismiss such actions without prejudice and to toll the statute of limitations.

Because Stephenson cannot establish the elements of a Bivens action until his conviction has been declared invalid or otherwise impugned as set out in Heck, the district court's order holding the case in abeyance is VACATED and the case is REMANDED to the district court for dismissal with prejudice. See Heck, ___ U.S. at ___-___, 114 S.Ct. at 2372-74.

Stephenson's additional motions — seeking leave to withdraw a petition for a writ of mandamus, and seeking to compel the appellees to respond to his brief in the instant case — are also DENIED.

VACATED AND REMANDED.


Summaries of

Stephenson v. Reno

United States Court of Appeals, Fifth Circuit
Aug 8, 1994
28 F.3d 26 (5th Cir. 1994)

holding that a federal prisoner's Bivens action is subject to the rule enunciated in Heck

Summary of this case from Cheek v. United States

holding that Heck is equally applicable to federal prisoners filing Bivens actions

Summary of this case from United States v. Austin

holding Heck applies to Bivens action

Summary of this case from Craig v. Lorraine

holding that claims stemming from criminal investigation, which led to subsequent conviction, were barred by Heck

Summary of this case from Blimline v. Thirty Unknown Emps. of the Sec. & Exch. Comm'n

holding Bivens action based on § 1985 claims subject to Heck

Summary of this case from Killen v. Hood

finding no distinction between state and federal prisoners in analysis of Bivens and § 1983 actions

Summary of this case from Ruff v. Runyon

finding that where a civil rights action implicates the validity of a conviction, there should be no distinction between state and federal prisoners; therefore, the analysis of a federal prisoner's Bivens-type action implicating a conviction "should parallel the analysis used to evaluate state prisoners' § 1983 claims"

Summary of this case from Mederos-Jimenez v. Miyar

concluding that the plaintiff'sBivens action was barred by Heck because it was "a challenge to the fact or length of his confinement"

Summary of this case from Mauro v. Freeland

affirming dismissal of claims under 42 U.S.C. § 1985 and RICO as barred by Heck

Summary of this case from Pate v. Johnson

affirming dismissal of claims under 42 U.S.C. § 1985 as barred by Heck

Summary of this case from Hernadez v. Kirkendall

affirming dismissal of claims under 42 U.S.C. § 1985 and RICO as barred by Heck

Summary of this case from Moreno v. Curry

recognizing that § 1983 action does not accrue until conviction or sentence has been invalidated

Summary of this case from Hulsey v. Owens

noting generally that if Heck applies, then the claims have not yet accrued and so the statute of limitations is not a concern

Summary of this case from Garrett v. United States

noting generally that if Heck applies, then the claims have not yet accrued and so the statute of limitations is not a concern

Summary of this case from O'Brien v. U.S. Fed. Gov't

applying Heck to a federal prisoner's civil rights claim

Summary of this case from Bernegger v. Grimmett

noting that if Heck applies, the claims have not yet accrued and so the statute of limitations is not a concern

Summary of this case from Hardy v. Gonzalez

applying Heck to a Bivens action pursuant to 28 U.S.C. § 1331 where plaintiff had not yet challenged the validity of his confinement. See Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388, 91 S.Ct. 1999, 29 L.Ed.2d 619

Summary of this case from Parris v. U.S.

explaining that if Heck applies to a claim, the claims have not yet accrued and so the statute of limitations is not a concern

Summary of this case from Howard v. Johson

applying the rule in Heck to a convicted federal prisoner's Bivens claim

Summary of this case from Rodarte v. Beneficial Tex. Inc.

noting that a federal prisoner's avenue to obtain a habeas corpus remedy is under 28 U.S.C. § 2255

Summary of this case from Davis v. Collins

In Stephenson v. Reno, 28 F.3d 26, 28 (5th Cir. 1994), the Fifth Circuit vacated a district court's decision holding a civil rights case in abeyance and remanded the case with instructions to dismiss the lawsuit with prejudice.

Summary of this case from Moore v. Fite

stating Heck applies to both state-inmate and federal-inmate plaintiffs

Summary of this case from STEWART v. TUCK

applying rule to actions brought by federal prisoners

Summary of this case from Ruston v. Dallas County, Texas

applying Heck to a Bivens claim

Summary of this case from Gay v. U.S.

applying Heck to a Bivens claim

Summary of this case from Chavez-Quezada v. Jesus
Case details for

Stephenson v. Reno

Case Details

Full title:OBADIAH STEPHENSON, SR., PLAINTIFF-APPELLANT, v. JANET RENO, UNITED STATES…

Court:United States Court of Appeals, Fifth Circuit

Date published: Aug 8, 1994

Citations

28 F.3d 26 (5th Cir. 1994)

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