Olivier v. City of Brandon, Mississippi
No. 24-993 · Decided March 20, 2026 · Reversed and remanded
Does the decision in *Heck v. Humphrey* bar a suit brought under 42 U.S.C. § 1983 that seeks only prospective relief? A suit brought under 42 U.S.C. § 1983 seeking purely prospective injunctive relief to prevent the future enforcement of a statute is not barred by *Heck v. Humphrey*, even if the petitioner was previously convicted under that statute.
Vote & lineup9–0 (unanimous) on the judgment. Kagan delivered the opinion for a unanimous Court (9).
The question
Does the decision in *Heck v. Humphrey* bar a suit brought under 42 U.S.C. § 1983 that seeks only prospective relief? Specifically, can a person who was previously convicted of violating a statute challenge that statute's constitutionality to prevent its future enforcement? The Court must determine if such a suit constitutes a prohibited collateral attack on a prior conviction.
Petitioner's argument
- Sought a declaration that the city ordinance violates the Free Speech Clause of the First Amendment and an injunction preventing its future enforcement.
- Argued that *Heck v. Humphrey* does not preclude a suit seeking "wholly prospective relief" rather than relief relating to a prior conviction.
- Contended that the *Heck* bar does not apply when the person suing was never in custody for the conviction and thus never had the opportunity to challenge it in federal habeas proceedings.
Respondent's argument
- Sought to have the suit barred from proceeding.
- Argued that under *Heck v. Humphrey*, a person previously convicted of violating a statute cannot challenge its constitutionality under 42 U.S.C. § 1983 because success would cast doubt on the prior conviction's correctness.
- Contended that the suit must be dismissed because a judgment in favor of the petitioner would "necessarily imply the invalidity" of the prior conviction.
The decision
- The Court held that a suit seeking purely prospective relief—an injunction stopping officials from enforcing an ordinance in the future—can proceed notwithstanding a prior conviction for violating that ordinance.
- The Court relied on *Wooley v. Maynard*, which allows § 1983 actions to prevent "further prosecution" to ensure citizens are not trapped "between the Scylla of intentionally flouting state law and the Charybdis of forgoing what he believes to be constitutionally protected activity."
- The Court distinguished this from *Heck v. Humphrey*, which prohibits "§ 1983 damages actions that necessarily require the plaintiff to prove the unlawfulness of his conviction or confinement" because such suits are "collateral attack[s]" on the conviction that intrude on the domain of habeas corpus.
- The Court noted that *Edwards v. Balisok* and *Wilkinson v. Dotson* established a line between *Heck* claims and those seeking "prospective injunctive relief" or "future relief," which are "distant" from the core of habeas.
- The Court rejected the respondent's reliance on the *Heck* phrase "necessarily imply the invalidity of his conviction or sentence," ruling that general language in judicial opinions must be read in context to similar circumstances, citing *Turkiye Halk Bankasi A. S. v. United States*.
- The Court reasoned that the *Heck* bar applies to suits that "look back" to conduct involved in a prior conviction to offer contradictory proof, whereas the petitioner's suit is "entirely future oriented."
- The Court concluded that because the petitioner does not seek to annul the results of his trial, expunge his record, or obtain monetary damages, the suit does not risk "parallel litigation" or "conflicting" judgments.