Background
Gregory L. Brown, a California state prisoner, appealed pro se from a district court judgment dismissing his action under Section nineteen hundred eighty-three of Title forty-two of the United States Code. Brown alleged various constitutional claims regarding his arrest, conviction, and sentencing in state court.
The court’s reasoning
The panel reviewed the dismissal de novo and affirmed because the district court correctly applied the rule from Heck versus Humphrey. The court found that Brown’s claims would necessarily imply the invalidity of his conviction or sentence, and he had not demonstrated that his conviction or sentence had been invalidated. The court also rejected Brown’s contention that the district court was not required to screen his complaint despite his payment of the filing fee, noting that the statute requires screening for any prisoner seeking redress from a governmental entity.
What it means going forward
This decision reinforces the strict application of the Heck bar for state prisoners filing Section nineteen hundred eighty-three actions and confirms that fee payment does not exempt complaints from mandatory screening.