Haywood v. Hathaway, 2016 U.S. App. LEXIS 21367

Haywood, an Illinois prisoner, was disciplined after accusing a teacher of attacking him: 60 days in segregation and one month of good-time credit revoked; he was later transferred to another prison.
Haywood sued under 42 U.S.C. § 1983 seeking money damages for (1) First Amendment retaliation/false-statement discipline and (2) Eighth Amendment cruel-and-unusual conditions during segregation (extreme cold, broken window, inadequate blankets/clothing).
The district court dismissed the First Amendment/damages claim under Heck/Edwards because the disciplinary sanction affecting custody duration had not been invalidated; it granted summary judgment to the warden on the Eighth Amendment claim based on lack of personal involvement by the warden.
On appeal, Haywood asserted his lost good-time credits had been restored and alternatively argued he waived any challenge to duration, so Heck should not bar his damages suit.
The Seventh Circuit affirmed dismissal of the First Amendment/damages claim (rejecting the Second Circuit’s Peralta approach) but reversed the summary judgment on the Eighth Amendment claim, finding factual material showing the warden knew of the conditions and responded inadequately such that deliberate indifference could be inferred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck/Edwards bars a § 1983 damages claim that would imply invalidity of a disciplinary sanction affecting custody duration	Haywood: his credits were restored (or he waived challenge to duration), so Heck should not bar damages now	Warden/State: Heck and Edwards bar § 1983 damages until the disciplinary decision has been set aside by appropriate means	Held: Affirmed dismissal—Heck/Edwards bars the damages claim until the sanction is invalidated; post-judgment restoration does not show district court error and waiver does not circumvent Heck
Whether Warden Hathaway is personally liable under the Eighth Amendment for extreme-cold conditions in segregation	Haywood: warden had actual knowledge (grievances, tour, storm) and took plainly inadequate steps—deliberate indifference	Warden: supervisor liability requires more than notice—Iqbal/Vance foreclose liability for mere knowledge or failure to fix subordinate misconduct	Held: Reversed summary judgment—evidence permits inference that the warden knew of and disregarded a substantial risk (deliberate indifference) and thus disputed material facts preclude summary judgment

Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 damages claim barred where success would imply invalidity of conviction unless conviction/sanction has been invalidated)
Edwards v. Balisok, 520 U.S. 641 (1997) (Heck applies to prison disciplinary proceedings that implicate duration of confinement)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas, not § 1983, is the appropriate vehicle for challenging fact or duration of confinement)
Wallace v. Kato, 549 U.S. 384 (2007) (explains Heck rationales and accrual principles for § 1983 claims tied to confinement)
Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate-indifference standard for conditions of confinement)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (supervisory liability requires more than mere knowledge in certain contexts)
Minneci v. Pollard, 565 U.S. 118 (2012) (recognizes continuing applicability of Farmer deliberate-indifference standard)