David Diaz filed a lawsuit under 42 U.S.C. § 1983 alleging that various Los Angeles police officers and officials conspired to obtain his false conviction in 1999. He sought damages for this alleged misconduct. The district court dismissed the action, ruling that the claims were barred by the Supreme Court's decision in Heck v. Humphrey. Diaz appealed, arguing that a commutation order from the Governor of California had invalidated his conviction and that he fell under an exception to the Heck bar because he was no longer in custody. The case also involved a prior 2001 lawsuit Diaz filed under the RICO statute regarding the same underlying facts, which had been dismissed with prejudice.
The Ninth Circuit affirmed the dismissal on two independent grounds. First, the court applied the Heck v. Humphrey bar, which prohibits § 1983 actions if a judgment in the plaintiff's favor would necessarily imply the invalidity of their conviction or sentence. The court found that Diaz's claim of a conspiracy to obtain a false conviction is incompatible with the validity of his 1999 conviction. Diaz argued that a commutation order from the Governor invalidated his conviction, but the court clarified that a commutation is merely a reduction in punishment, not a pardon or expungement. As the court noted, a commutation 'is a reduction in punishment,' whereas a 'pardon' is the 'remission of guilt.' Because the conviction remains valid, the Heck bar applies. The court also rejected Diaz's reliance on the Nonnette exception, which allows former prisoners to challenge the loss of good-time credits when habeas relief is moot. The court explained that Nonnette does not extend to challenges of the underlying conviction itself, where habeas corpus remains available. Second, the court applied the doctrine of res judicata, or claim preclusion. The court found that Diaz's current § 1983 suit arose from the same transactional nucleus of facts as his 2001 RICO suit. Since the 2001 suit involved the same defendants and resulted in a final judgment on the merits, Diaz is barred from relitigating those claims.
The dismissal of Diaz's § 1983 action stands, meaning he cannot pursue damages for the alleged conspiracy to obtain his conviction. The decision reinforces that a commutation order does not clear a conviction for the purposes of the Heck bar. It also confirms that res judicata will block § 1983 suits that are based on the same factual core as a prior dismissed RICO or other civil action. The ruling leaves open the question of whether Diaz can still pursue habeas corpus relief to challenge the validity of his conviction, as the court noted that habeas remains available for such challenges even after release.
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