Muhammad, Aka Mease v. Close

Summary

The Court unanimously held, per curiam, that Heck’s favorable-termination requirement does not bar a prisoner’s § 1983 action when success would not imply the invalidity of his conviction or the duration of his sentence. Muhammad sought damages for allegedly retaliatory prehearing detention, not expungement of his disciplinary conviction, and the challenged action had not affected good-time credits on the record before the Court. Close waived his contrary contention by failing to raise it below. The Court reversed and remanded for consideration of the District Court’s conclusion that Muhammad had insufficient evidence of retaliation. There were no separate opinions.