City of Santa Maria, California, et al. v. Adolfo Cardenas

In Heck v. Humphrey, 512 U.S. 477 (1994), this Court held that a Section 1983 damages claim must be dismissed where a judgment in the plaintiff’s favor would necessarily imply the invalidity of his criminal conviction. Here, the district court found application of the Heck bar “rather straightforward.” App. 17a. Respondent pleaded no contest to resisting arrest after leading officers on a high-speed chase, fleeing on foot, and charging at an officer before being tased. But then he sued the City and one of its officers alleging use of the taser to take him into custody was excessive force. Under Heck, that claim cannot proceed. Yet a divided Ninth Circuit panel reversed. The majority first held that the record did not clearly establish the factual basis for respondent’s no-contest plea—even though, as Judge Koh explained in her separate opinion, respondent repeatedly conceded that the entire police report, which included a detailed description of why and how the taser was employed, formed the factual basis for respondent’s plea. In the alternative, the panel invoked the nowvacated decision in King v. Villegas, 156 F.4th 979 (9th Cir. 2025), vacated, 171 F.4th 1163 (9th Cir. 2026), which held that Rule 410(a) of the Federal Rules of Evidence categorically bars a defendant from ever invoking a plaintiff’s no-contest plea as a basis for a Heck dismissal. The question presented is whether a court may refuse to apply the Heck bar in such circumstances.