Muhammed v. Close
Prison inmate Shakur Muhammad brought suit against correctional officer Mark Close, alleging that Close falsely charged him with misconduct. Muhammad sought damages and the removal of his misconduct conviction from his record. In Heck v. Humphrey, the Supreme Court set forth requirements inmates must meet to recover damages for a civil rights action under 42 U.S.C. ยง 1983 when a finding in their favor would invalidate the conviction or sentence. Here, however, Muhammad challenged the conditions of his confinement–caused by conviction on the allegedly false misconduct charge–rather than his initial conviction or sentence. The district court granted summary judgment in favor of Close and the court of appeals affirmed in an unpublished opinion.
Questions Presented:
1. Whether a plaintiff who wishes to bring a Section 1983 suit challenging only the conditions, rather than the fact or duration, of his confinement, must satisfy the favorable termination
requirement of Heck v. Humphrey.
2. Whether a prison inmate who has been, but is no longer, in administrative segregation may bring a Section 1983 suit challenging the conditions of his confinement (i.e. his prior placement in
administrative segregation) without first satisfying the favorable termination requirement of Heck v. Humphrey.
Decision under Review: 47 Fed. Appx. 738 (6th Cir. 2002)
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