Williams v. Dixon

Background

Josephus H. Williams, a state prisoner at California State Prison in Solano, filed a civil-rights action without a lawyer under 42 U.S.C. § 1983. He alleged that he was placed in administrative segregation on February 2, 2018, after being accused of distributing controlled substances, later found guilty, and denied the right to call witnesses at his disciplinary hearing. Williams sought restoration of good-time credits and other relief. The court stated that his motion to proceed without paying the filing fee would be addressed in a separate order.

Court’s analysis

The court conducted the required preliminary screening of a prisoner’s complaint. It explained that claims challenging the fact or duration of confinement must generally be brought through a habeas petition, while claims challenging the conditions of confinement may be brought under § 1983.

The court concluded that Williams’s claim challenged the revocation of good-time credits. If the credits were restored, that would necessarily result in earlier release. The court therefore held that the claim had to be brought as a petition for a writ of habeas corpus under 28 U.S.C. § 2254 rather than as a § 1983 action. The court did not decide whether Williams was actually denied due process at the disciplinary hearing.

The court also explained that a § 1983 claim for damages based on the deprivation of time credits could proceed only after the underlying disciplinary result had been invalidated through one of the methods identified in Heck v. Humphrey, including a successful habeas proceeding.

Disposition

The court DISMISSED the action without prejudice to Williams filing a new habeas action under 28 U.S.C. § 2254. The clerk was directed to send Williams two copies of the court’s habeas petition form along with the order.