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Wilkinson v. Dotson

Docket No.: 03-287
Certiorari Granted: Mar 22 2004
Argued: December 6, 2004
Decided: March 7, 2005

Topics:

Reconstruction Civil Rights Acts (42 USC 1983), Criminal Procedure, Habeas Corpus, Civil Rights Act, Due Process, EPA, Section 1983, disparate impact, disparate treatment, equitable relief, habeas, habeas corpus, jury selection, murder, racial discrimination

PartyNames: Reginald A. Wilkinson, Director, Ohio Department of Rehabilitation and Correction, et al. v. William Dwight Dotson, et al.
Petitioner: Reginald A. Wilkinson, Director, Ohio Department of Rehabilitation and Correction, et al.
Respondent: William Dwight Dotson, et al.

Court Below: United States Court of Appeals for the Sixth Circuit
Citation: 300 F3d 661 and 329 F3d 463
Supreme Court Docket

Reginald A. Wilkinson, Director, Ohio Department of Rehabilitation and Correction, et al.
v.
William Dwight Dotson, et al.
544 U.S. 74 (2005)
Background:

This petition arises from one of the many cases considering which prisoner claims are barred by Heck v. Humphrey, 512 U.S. 477 (1994). Heck holds that a prisoner cannot advance a claim under 42 U.S.C. § 1983 where success on that claim would "necessarily imply the invalidity of his conviction or sentence...unless...the conviction or sentence has already been invalidated." Id. at 487. This is Heck's so- called "favorable termination requirement." The Sixth Circuit concluded below that Heck's favorable termination requirement does not cover claims challenging parole procedures because success on those claims would not necessarily guarantee speedier release, but instead would provide only a new parole hearing. This raises the following questions:

Question Presented:

1. When a prisoner invokes § 1983 to challenge parole proceedings, does Heck v. Humphrey's favorable termination requirement apply where success by the prisoner on the claim would result only in a new parole hearing and not necessarily guarantee earlier release from prison? 2. Does a federal court judgment ordering a new parole hearing "necessarily imply the invalidity of" the decision at the previous parole hearing for purposes of Heck v. Humphrey?

Question:

(1) May a prisoner bring a claim under 42 U.S.C. 1983 claiming that his parole proceedings violate due process, even though success on the merits of the claim would result only in a new parole hearing and would not necessarily guarantee earlier release from prison? (2) Does a federal court judgment ordering a new parole hearing "necessarily imply the invalidity of" the decision at the previous parole hearing and therefore challenge the sentence itself?

Wilkinson v. Dotson
ORAL ARGUMENT

December 6, 2004

Holding: is affirmed and remanded
Decision: Decision: 8 votes for Dotson, 1 vote(s) against
Vote: 8-1
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