S.D.Ga.: Heck explained in 4A terms

Explaining Heck: This case involves alleged illegally admitted statements, but it’s explained in terms of the Fourth Amendment. Edwards v. Perry, 2019 U.S. Dist. LEXIS 74480 (S.D. Ga. May 3, 2019):

Some § 1983 claims, due to their very nature, are incompatible with the conviction as a matter of law. Id. at 879. Other claims, however, can resolve in the plaintiff’s favor without disturbing the conviction because, even after a successful claim, there remains an independent “construction of the facts that would allow the underlying conviction to stand.” Id. For example, Fourth Amendment claims related to unreasonable searches and seizures are not necessarily barred under Heck, even when the evidence was admitted at trial, because “illegal searches may be followed by valid convictions.” Harvey v. United States, 681 F. App’x 850, 853 (11th Cir. 2017) (citing Heck, 512 U.S. at 487 n.7) (“[A] suit for damages arising out of an allegedly unreasonable search … may proceed even if evidence from the challenged search was introduced in the criminal trial that resulted in the plaintiff’s conviction.”). This is because other evidence might support the conviction or other legal doctrines (e.g., inevitable discovery, independent source) could provide alternative grounds for admissibility. Harvey, 681 F. App’x at 853 (citing Heck, 512 U.S. at 487 n.7); Pritchett v. Farr, 592 F. App’x 816, 819 (11th Cir. 2014); Hughes v. Lott, 350 F.3d 1157, 1161 (11th Cir. 2003). In such a circumstance, courts “must ‘look both to the claims raised under § 1983 and to the specific offenses for which the § 1983 claimant was convicted.'” Harvey, 681 F. App’x at 853-54 (11th Cir. 2017) (quoting Hughes, 350 F.3d at 1160 n.2). “When the circumstances surrounding a conviction cannot be discerned from the record” and it is otherwise “impossible for a court to determine whether a successful § 1983 damages action … would necessarily imply that the conviction is invalid,” the claim is not barred by Heck. Id. at 853 (quoting Hughes, 350 F.3d at 1160 n.2).

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