Jessie Harrison v. State of Michigan
2013 U.S. App. LEXIS 13892
| 6th Cir. | 2013Background
- Harrison was convicted in 1986 of reckless use of a firearm resulting in death and felony-firearm, with consecutive sentences that Michigan law treated as concurrent.
- He was released from prison in March 1990 after serving 18 months beyond the statutory maximum for the 1986 offenses.
- In 1991 Harrison committed another firearm offense and was returned to prison.
- In 2003 Harrison obtained a Michigan post-conviction ruling that his 1986 sentence was improper (the 1986 felony-firearm could not run concurrent to the misdemeanor), and the state court later issued a corrected judgment in 2008.
- Harrison filed this §1983 action in 2010 against the State, MDOC, Parole Board, Governor, and others seeking damages for the 18 months served beyond the 1986 maximum and for failure to commute the 1991 sentence; the district court dismissed on sovereign immunity and statute-of-limitations grounds; the Sixth Circuit reversed on timeliness and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the §1983 claim is time-barred | Harrison contends accrual occurred in 2010 or upon favorable state judgment | Defendants argue accrual based on Wallace v. Kato false-arrest rule | Not time-barred; accrual tied to Heck favorable termination (2008) |
| Whether sovereign immunity bars the claims against state actors | Harrison asserts against state actors for damages | Eleventh Amendment immunity shields MDOC and Parole Board; state not a proper §1983 defendant | State entities immune; claims against MDOC and Parole Board dismissed |
| Whether Heck v. Humphrey governs accrual here | Heck does not apply because sentence was invalidated favorably | Heck applies; requires favorable termination before §1983 can proceed | Heck applies; favorable termination occurred in 2008; timely when filed in 2010 |
Key Cases Cited
- Wallace v. Kato, 549 U.S. 384 (U.S. 2007) (false-arrest accrual rule; accrual at arrest not applicable to invalid convictions/sentences)
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (favorable-termination requirement for §1983 claims relating to convictions/sentences)
- Spencer v. Kemna, 523 U.S. 1 (U.S. 1998) (concurring opinion discussion of Spencer holding and its limits on Heck)
- Ruff v. Runyon, 258 F.3d 498 (6th Cir. 2001) (recognizes accrual when plaintiff knows injury but Heck may delay relief)
- Powers v. Hamilton Cnty. Pub. Defender Comm'n, 501 F.3d 592 (6th Cir. 2007) (limits Spencer exception to cases where habeas relief was unavailable)
- Collyer v. Darling, 98 F.3d 211 (6th Cir. 1996) (distinguishable; accrual rule for §1983 depends on when injury is known)