Jeryme Morgan v. Minh Schott, et al.

When an inmate is penalized for a disciplinary infraction, prison officials may impose durational sanctions (e.g., revoking good-time credits) or nondurational sanctions (e.g., reducing prison privileges). Often, officials will impose both durational and nondurational sanctions in the same disciplinary proceeding—a so-called “mixed-sanctions” case. Heck v. Humphrey, 512 U.S. 477 (1994), and Edwards v. Balisok, 520 U.S. 641 (1997), bar an inmate from seeking damages under 42 U.S.C. § 1983 for disciplinary action resulting in durational sanctions unless the adverse disciplinary findings have been invalidated or set aside in a separate proceeding. In contrast, this “Heck bar” does not apply to an inmate seeking damages under § 1983 for nondurational sanctions. The question posed in this case involves application of the Heck bar to a mixedsanctions case—a frequently recurring issue that is the subject of an acknowledged circuit split. Specifically, the question that has split the circuits, presented cleanly here, is whether Heck bars § 1983 claims for damages in mixed-sanctions cases where the inmate challenges only the non-durational elements of the sanction, expressly forfeiting the right to challenge any addition to the length of his criminal sentence.