McKnight v. Nevada Board of Parole Commissioners, 3:13-cv-00111

Plaintiff Marcel McKnight, a state prisoner, filed a pro se § 1983 civil rights complaint against the Nevada Board of Parole Commissioners seeking damages, restoration of good-time credits, rescission of a parole revocation, and to enjoin an extradition order.
McKnight filed an application to proceed in forma pauperis (IFP) but did not use the court’s required form and failed to submit a six-month inmate account statement and a properly executed prison financial certificate.
The Court reviewed the complaint under the screening standards of 28 U.S.C. §§ 1915A and 1915(e)(2) and Rule 12(b)(6), applying liberal construction for pro se pleadings but requiring plausible factual allegations per Twombly/Iqbal.
The complaint seeks relief that would implicate the validity or duration of McKnight’s confinement (restoration of credits, reversal of parole revocation), so the Court treated the claims as collateral attacks on his conviction/term of imprisonment.
Because McKnight’s conviction/sentence has not been invalidated, the Court found his § 1983 claims barred by Heck and concluded they fail to state a cognizable civil-rights claim; amendment was deemed futile.
The Court denied IFP status, dismissed the civil rights action with prejudice, certified an IFP appeal would not be taken in good faith, and advised McKnight he may instead file a § 2254 habeas petition (and provided forms) in a new action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of IFP application	McKnight sought pauper status to proceed without prepayment of fees	Defendants (via court) note McKnight failed to use required form and omitted required inmate account statement and financial certificate	IFP denied for failure to comply with local and statutory requirements
Proper vehicle for relief attacking conviction/duration of confinement	McKnight framed requests (restoring credits, reversing parole revocation, enjoining extradition) as civil-rights claims seeking damages and equitable relief	Court (and defendants) contended such relief attacks the validity/duration of confinement and belongs in habeas corpus, not § 1983	Claims construed as collateral attacks on conviction; habeas is the proper vehicle
Viability of § 1983 damages claim while conviction stands	McKnight sought damages tied to the conviction/parole revocation	Defendants invoked Heck: damages tied to an uninvalidated conviction are not cognizable under § 1983	Dismissed: § 1983 damages claim barred by Heck because conviction has not been invalidated
Leave to amend	McKnight implied entitlement to pursue civil-rights claims in this action	Court considered whether defects could be cured by amendment	Amendment would be futile as claims necessarily challenge the conviction; action dismissed with prejudice and without leave to amend

West v. Atkins, 487 U.S. 42 (1988) (elements for § 1983 liability: constitutional violation and action under color of state law)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus is sole federal remedy for prisoners challenging the fact or duration of confinement)
Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claim barred if success would necessarily imply invalidity of conviction or sentence unless conviction overturned)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim for relief; labels and conclusions insufficient)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions must be supported by factual allegations to plausibly state a claim)
Neitzke v. Williams, 490 U.S. 319 (1989) (courts may sua sponte dismiss in forma pauperis claims lacking an arguable basis in law or fact)