City of Fairbanks, Alaska, et al. v. Marvin Roberts, et al.

In Heck v. Humphrey, 512 U.S. 477 (1994), this Court held that a plaintiff cannot bring a claim under 42 U.S.C. § 1983 for allegedly unconstitutional conviction or imprisonment unless they can prove that the underlying criminal proceedings terminated in their favor. Heck identified four possible ways that a § 1983 plaintiff could overcome this bar—namely, a plaintiff “must prove that the conviction or sentence has been [1] reversed on direct appeal, [2] expunged by executive order, [3] declared invalid by a state tribunal authorized to make such determination, or [4] called into question by a federal court’s issuance of a writ of habeas corpus.” Heck, 512 U.S. at 486-87 (numbering added). Respondents were convicted and imprisoned for a 1997 murder in Fairbanks, Alaska. During the pendency of state post-conviction proceedings, an Alaska trial court vacated Respondents’ convictions based on a settlement agreement and a stipulation with the state that “the original jury verdicts and judgments of conviction were properly and validly entered based on proof beyond a reasonable doubt[.]” In vacating the convictions, the Alaska court made no determination that the convictions were unlawfully obtained or constitutionally infirm. To the contrary, the Alaska court expressly stated that its review was limited to examining whether the state attorney general acted within his lawful authority to settle civil litigation and that the court was not opining on the merits of the underlying convictions or the terms of the settlement. On review, the issue is whether vacatur of a conviction by settlement qualifies as a favorable termination under Heck when the vacatur was merely the ministerial recognition of a settlement agreement between Respondents and the state.