The question
Whether the Heck v. Humphrey bar prevents a plaintiff with a prior conviction under a challenged ordinance from bringing a Section 1983 suit that seeks only prospective relief against future enforcement of that ordinance.
Olivier v. City of Brandon
What the Court decided
The Court held that Olivier's Section 1983 suit seeking purely prospective relief can proceed despite his prior conviction under the challenged ordinance. Heck v. Humphrey does not bar the suit because Heck applies to damages actions that necessarily require proving the unlawfulness of a conviction, not to a suit seeking only an injunction against future enforcement. A suit for wholly prospective relief falls within the heartland of Section 1983 and is not a collateral attack on the validity of a conviction. The Court reversed and the suit may go forward.
How the justices split
UnanimousThe Court's opinion
Kagan, joined by Roberts, Thomas, Alito, Sotomayor, Gorsuch, Kavanaugh, Barrett, Jackson
Writing for a unanimous Court, Kagan concluded that Olivier's Section 1983 suit for purely prospective relief may proceed despite his prior conviction under the ordinance. The opinion explained that such a suit falls within the heartland of Section 1983, allowing a plaintiff facing a credible threat of prosecution to challenge a local law and prevent its future enforcement, and that Wooley v. Maynard applied this rule even to a plaintiff previously convicted under the challenged law. The opinion distinguished Heck v. Humphrey, which bars Section 1983 damages actions that necessarily require proving the unlawfulness of a conviction because they operate as a collateral attack on the conviction and intrude on the habeas statute's domain, and held that a suit seeking only to be free from future prosecutions is not designed to annul a prior conviction and so is not barred.
How we know · 5 sourced claims
The Court held that Olivier's Section 1983 suit seeking purely prospective injunctive relief can proceed notwithstanding his prior conviction for violating the challenged ordinance.
Source: syllabus, Held
The Court held that Heck v. Humphrey does not bar the suit.
Source: syllabus, Held
The Court explained that Heck bars Section 1983 damages actions that necessarily require the plaintiff to prove the unlawfulness of his conviction or confinement.
Source: syllabus, Held
The Court relied on Wooley v. Maynard, which applied the rule permitting prospective Section 1983 challenges even when the plaintiff was previously convicted under the challenged law.
Source: syllabus, Held
Kagan delivered the opinion for a unanimous Court.
Source: syllabus, lineup