CA11: A rare reversal of application of the Heck bar to prisoner § 1983 case

The district court erred in applying the Heck bar to plaintiff’s pro se complaint. There is a possibility he can get it to trial without implicating the validity of the conviction. Pritchett v. Farr, 2014 U.S. App. LEXIS 21965 (11th Cir. November 21, 2014)*:

Second, the district court may have confused the legality of the search with the validity of the conviction. When it overruled Pritchett’s objection, the court did so on the ground that “the search and seizure about which [he] complains could not be considered appropriate under any other legal doctrine, e.g., independent source.” But the exception to Heck’s bar turns on whether a judgment for Pritchett in this § 1983 suit would necessarily imply the invalidity of his state court convictions, not on whether the search of his house could “be considered appropriate.” See Heck, 512 U.S. at 487 n.7, 114 S.Ct. at 2372 n.7.

Nor do the allegations in Pritchett’s complaint foreclose the possibility that his state convictions “might still be valid” in light of the doctrines discussed in Heck. See Datz, 51 F.3d at 253 n.1 (citing Heck, 512 U.S. at 487 n.7, 114 S.Ct. at 2372 n.7). For instance, it may well be the case that the information from Pritchett’s phone introduced at trial — which we assume (for present purposes only) was text messages or records of phone calls to the victim — would have been admissible under the inevitable discovery doctrine because the police conceivably could have discovered that same evidence by looking at the victim’s phone. See id.; cf. Kabat v. State, 867 So. 2d 1153, 1157 (Ala. Crim. App. 2003) (discussing “the inevitable-discovery exception” in Alabama criminal trials).