Bibbs v. Macay

Background

Martin J. Bibbs, a state prisoner incarcerated at R. J. Donovan Correctional Facility, filed a complaint without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for constitutional violations by people acting under state law. He alleged that, while incarcerated at Salinas Valley State Prison in 2022, he was denied due process in connection with a rules violation report concerning possession of a cellular telephone. He said prison officials did not give him a copy of the incident report before the disciplinary hearing, which prevented him from having a fair opportunity to present a defense.

Bibbs was found guilty and assessed a loss of 90 days of good-time credits. He sought reversal of the guilty finding, restoration of those credits, and compensatory and punitive damages.

Screening and legal analysis

Under 28 U.S.C. § 1915A, federal courts must screen prisoner complaints seeking relief from a governmental entity or officer. The court must dismiss a complaint, or part of it, if it is frivolous, malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also noted that complaints filed without a lawyer must be read generously.

The court held that Bibbs’s challenge had to be brought in a petition under 28 U.S.C. § 2254 challenging the legality or duration of his custody, rather than under § 1983. Reversing the disciplinary finding and restoring the 90 days of good-time credits would necessarily result in faster release from state custody, so the claim fell within the core of custody-challenge proceedings.

The court also applied the rule from Heck v. Humphrey. Under that rule, a § 1983 plaintiff generally cannot obtain damages for an allegedly unconstitutional conviction, sentence, or imprisonment when success would imply that the underlying judgment is invalid, unless that judgment has already been reversed, expunged, declared invalid, or set aside through a federal custody-challenge proceeding. The court stated that this rule also barred Bibbs’s claim that he was denied proper disciplinary-hearing procedures because that challenge necessarily implied that the disciplinary judgment was invalid.

Disposition

The complaint was dismissed under 28 U.S.C. § 1915A(b) for failure to state a claim under § 1983 upon which relief may be granted. The dismissal was without prejudice to Bibbs filing a § 2254 petition after exhausting state judicial remedies, or filing a § 1983 damages complaint after invalidating the 2022 disciplinary finding that resulted in the loss of 90 days of good-time credits. Judge Charles R. Breyer signed the order.