Background
California state prisoners Allen Auten, Mario King, Bruce Koklich, Jared Manely, and Lawrence Remsen appealed pro se from a district court judgment dismissing their Section nineteen eighty-three action related to good-time credits. The plaintiffs also alleged district court bias and misconduct and sought civil contempt and damages.
The court’s reasoning
The panel reviewed the dismissal de novo and concluded the district court properly barred the action under Heck v. Humphrey. The court explained that success on the plaintiffs’ claims would necessarily imply the invalidity of their sentences. Because the plaintiffs failed to allege facts demonstrating that their sentences had been invalidated, the claims were barred. The court also rejected unsupported contentions regarding district court bias and denied the motion for civil contempt.
What it means going forward
The ruling reinforces that prisoners cannot use Section nineteen eighty-three actions to challenge good-time credits unless they first invalidate their underlying sentences through other means.
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