Thomas Charles Horne, et al. v. Sheila Sullivan Polk
AdministrativeLaw DueProcess FourthAmendment
whether-the-heck-rule-should-apply-to-administrative-cases
QUESTION PRESENTED The question presented concerns the Heck rule of this Court (Heck v. Humphrey, 512 U.S. 477 (1964). In that case, this Court held, in the criminal context, that the statute of limitations for a section 1983 action runs from the reversal of the judgment which is the subject of the 1983 action, not from when plaintiff should have known of the violation of his rights. The rule has been applied in civil administrative cases involving prisoner discipline. The question is whether it should be applied as well in other administrative cases, such as this one, where the policy basis for the rule, articulated in Heck, would also apply here, and where defendants were denied property without due process of law.