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Decided: October 27, 2015

The Fourth Circuit affirmed the district court’s ruling.

In 1982, Plaintiff, Wendell Griffin was convicted for the murder of James Williams Wise and also for related weapons charges. In June of 2010, Griffin filed a pro se petition seeking post-conviction DNA testing of certain evidence. Griffins’ appointed counsel filed a Maryland Public Information Act request, which provided documents that allegedly revealed that Baltimore City Police Department detectives withheld from the defense certain exculpatory evidence.  On February 2, 2012, Griffin moved for state post-conviction relief and on May 23, 2012, Griffin was placed on three years unsupervised probation. Griffin then sued the Baltimore City Police Department and three of its former detectives under 42 U.S.C. § 1983 for damages. The district court dismissed his claims pursuant to the bar set forth in Heck v. Humphrey, stating that Griffin had “ample opportunity to seek federal review . . . prior to his release from incarceration.”

In Heck, the United States Supreme Court prohibited § 1983 claims from implicating issues more appropriately resolved via federal habeas corpus or state post-conviction relief. Griffin argued that his claims were not subject to Heck because they fell under an exception recognized in Wilson v. Johnson. Wilson recognizes an exception to the Heck bar in cases where a litigant could not have sought habeas corpus relief while in custody. The Court found, however, that Griffin did not lack access to habeas relief while he was in custody. Griffin had three decades to seek habeas relief, whereas Wilson only had a few months to make a habeas claim. Griffin was even able to bring a federal habeas claim while in custody. Although his petition was denied, the fact that he was able to file it demonstrates the differences between his case and Wilson. Therefore, the Court found that Griffin had no obstruction to habeas access allowing an expansion of the Heck exception. The Court noted that its decision sounded in procedure and not substance. Its holding was not meant to bar Griffin from seeking a remedy for possible police misconduct, only that the vehicle he chose was not appropriate under Supreme Court and circuit precedent.

Accordingly, the Court affirmed the judgment of the district court.

Full Opinion

Meredith Weisler