By Eric Benedict
On October 27th, 2015, the Fourth Circuit issued its published opinion in the civil case, Griffin v. Baltimore Police Dept. In Griffin, the Fourth Circuit affirmed the District Court’s determination that Griffin’s § 1983 claim (42 U.S. Code § 1983) was barred by the standards set forth in Heck v. Humphrey. The Heck rule prohibits § 1983 claims that would “necessarily imply[y] the invalidity of a prior conviction.” The Court explained that because, if successful, Griffin’s “Brady Claim” would imply that his conviction was invalid, and was therefore barred by Heck.
Griffin’s Conviction and Pursuit of Post-Conviction Relief
In 1982, a Baltimore jury convicted Wendell Griffin of murder and a related weapons charge. Griffin was then sentenced to life in prison. The state appellate court affirmed the conviction and Maryland’s highest state court declined to hear his appeal. Fifteen years after his conviction, Griffin fined a petition for habeas corpus in the United States District Court for the District of Maryland. That petition was ultimately denied and the Fourth Circuit declined to issue a certificate of appealability. Finally, Griffin filed a petition seeking DNA testing on pieces of evidence from the police case file. As part of the proceedings that followed, Griffin apparently discovered information that suggested the police failed to hand over exculpatory evidence to the defense during trial. Griffin was ultimately successful in reducing his sentence from a life sentence to time served.
Griffin Files Suit Against the Baltimore City Police Department
After his release, Griffin filed a § 1983 claim against the Police Department. A § 1983 claim allows a plaintiff to seek damages against an actor who violates the plaintiff’s federal rights while acting under color of state law. Griffin claimed that the Baltimore Police Department withheld evidence that would have exculpated him at trial (a “Brady Claim”).
Heck’s Judgment Consistency Precludes Griffin’s Claim
The Fourth Circuit relied heavily on precedent to prevent Griffin’s claim from moving forward. Specifically, the Court cited the consistency standards set for in Heck v. Humphrey. In Heck, a 1994 United States Supreme Court case, the Supreme Court explained that allowing a plaintiff to proceed on a § 1983 claim that would imply the wrongfulness of a still-valid conviction would lead to inconsistent results. On one hand, there would be a standing conviction, not overturned at the state or federal level, while on the other there would be a civil judgment calling that conviction into question. The Fourth Circuit reasoned that any successful “Brady Claim” would undermine Griffin’s prior conviction because it would call into question the validity of the verdict.
The Heck Court expressly allowed claims like Griffin’s to move forward only when the conviction had already been “reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal…or called into question by a federal court’s issuance of a writ of habeas corpus.” Griffin argued that because he was no longer incarcerated, the habeas corpus path was no longer accessible to him, and therefore, he should be allowed to proceed. The Fourth Circuit explained that such an exception should only be available where a plaintiff cannot seek habeas relief as a practical matter (i.e. a short sentence). The Court noted that Griffin had ample time to seek habeas relief, and indeed did at one point, although his petition was denied. Additionally, Griffin had at least sixteen months after learning about the alleged Brady claim to seek habeas relief, but did not. In sum, the Court concluded that the suit was barred by the limits of Heck, and that Griffin did not fall into any exception to the rule.
The Court Recognizes Federalism Concerns in Post-Conviction Relief
Citing the unique relationship between state and federal courts, the Fourth Circuit acknowledged the delicate balance between a state court’s interest in a given conviction and a federal court’s use of habeas corpus. The Fourth Circuit reasoned that limitations on habeas relief are especially warranted when a state provides pathways for post-conviction relief. In Maryland, the Fourth Circuit identified four: a petition for error coram nobis, a petition for writ of actual innocence on the basis of newly discovered evidence, a pardon from the Governor, and Maryland’s standard direct and collateral review procedures. The Court explained that should Griffin’s petition be invalidated through a method still available to him, the Heck rule would no longer apply, and Griffin could pursue a § 1983 claim.
The Fourth Circuit Affirms
The Fourth Circuit affirmed the District Court’s dismissal of Griffin’s claim. Both the majority opinion and the lone concurrence were careful to articulate that their ruling only discusses the procedural aspects of the claim and not the merits. Should Griffin’s conviction become invalidated, he may be able to pursue his claim.