CA3: Appellate order reversing revo overcame Heck bar

Plaintiff had his probation revoked and reversed it on appeal. The appellate court’s order, although not addressing his specific issue, was still a termination in his favor for the Heck bar in a § 1983 case for wrongful prosecution. “This appeal raises a discrete issue involving claims for damages for unlawful incarceration brought under 42 U.S.C. § 1983. We must decide whether an order from the Superior Court of Pennsylvania vacating a sentence imposed by a court of common pleas constitutes a favorable termination of the proceedings against a plaintiff within the meaning of Heck v. Humphrey — notwithstanding the fact that the order failed expressly to address the inmate’s specific legal challenges to the sentence. For the reasons that follow, we hold that such an order constitutes a favorable termination of the proceedings against the plaintiff and that any § 1983 claims stemming from the invalidated sentence are not barred by Heck. Accordingly, we will affirm in part and reverse in part the District Court’s order dismissing Appellant’s claims.” Bronowicz v. Allegheny County, 2015 U.S. App. LEXIS 16769 (3d Cir. September 22, 2015).