116 F.4th 301
4th Cir.2024Background
- Jonathan Brunson, a North Carolina prisoner, filed a § 1983 suit seeking relief from state officials after four other § 1983 claims of his had been dismissed under the rule from Heck v. Humphrey.
- The Prison Litigation Reform Act (PLRA) bars prisoners with three or more prior qualifying dismissals from proceeding in forma pauperis (IFP) (without prepaying filing fees).
- Brunson argued that his prior dismissals under Heck should not be counted as “strikes” under the PLRA’s three-strikes provision.
- The district court found that Brunson’s prior Heck dismissals counted as strikes, so he had to prepay the fee; later, his complaint was dismissed for unrelated reasons.
- On appeal, the Fourth Circuit considered whether Heck-based dismissals constitute “failure to state a claim” under the PLRA and therefore count as strikes against IFP status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do dismissals under Heck v. Humphrey count as strikes under PLRA? | Heck dismissals don’t qualify as strikes because they don’t address merits but timing and are more akin to an affirmative defense. | Heck dismissals are for failure to state a claim and should count as strikes. | Yes; such dismissals are for failure to state a claim and count as PLRA strikes. |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (defines the favorable-termination requirement for certain § 1983 claims involving convictions or sentences)
- Jones v. Bock, 549 U.S. 199 (discusses the PLRA’s three-strikes rule intended to filter nonmeritorious claims)
- Coleman v. Tollefson, 575 U.S. 532 (confirms PLRA’s role in filtering prisoner litigation)
- Estelle v. Gamble, 429 U.S. 97 (failure to plead a required element leads to dismissal for failure to state a claim)
- Bell v. Hood, 327 U.S. 678 (absent cause of action does not defeat subject-matter jurisdiction)