Background
Calvin Williams sued Moberly Correctional Center and two officials over conditions of his confinement and sought permission to proceed in forma pauperis, without prepaying the filing fee. The district court denied that request under the Prison Litigation Reform Act’s three-strikes rule after determining that three of Williams’s prior suits had been dismissed for failure to state a claim.
On appeal, Williams challenged the treatment of one prior suit as a strike because it had been dismissed under Heck v. Humphrey. He argued that a Heck-barred action is premature rather than deficient for failure to state a claim and that his earlier action should instead be treated as a habeas petition.
The Court’s Holding
The Eighth Circuit affirmed. Relying on its precedent in Schafer v. Moore, the court held that a dismissal under Heck is a dismissal for failure to state a claim and therefore counts as a strike under 28 U.S.C. § 1915(g). When success on a Section 1983 claim would necessarily imply that a conviction or sentence is invalid, favorable termination is an element that the plaintiff must plausibly allege.
The court rejected Williams’s attempt to characterize the earlier dismissal as involving prematurity, exhaustion, abstention, or habeas relief. His prior complaint sought damages and injunctive relief under Section 1983 for allegedly unconstitutional prison discipline and segregation, not immediate or speedier release, and the court declined to rewrite it retroactively as a habeas petition.
Key Takeaways
- In the Eighth Circuit, a Heck-barred Section 1983 action is dismissed for failure to state a claim.
- A Heck dismissal counts as a strike under the PLRA’s three-strikes rule.
- Courts will not reclassify a prior prison-discipline suit seeking damages and injunctive relief as a habeas petition merely to avoid a PLRA strike.
Why It Matters
The decision reaffirms the Eighth Circuit’s position in a circuit split over whether Heck dismissals categorically count as PLRA strikes. Prisoners litigating in the circuit may therefore lose eligibility to proceed in forma pauperis based on prior Section 1983 claims dismissed for failure to satisfy Heck’s favorable-termination requirement.