Rollins v. Willett, 770 F.3d 575

Plaintiff Rodney Rollins drove into an Aldi parking lot, exited his car, and was ordered by a police officer who had pulled up behind him to get back into the car and produce license, registration, and insurance.
Rollins refused, two additional officers arrived, he was arrested, and two months later pleaded guilty to driving on a suspended or revoked license.
Rollins sued under 42 U.S.C. § 1983, alleging an unreasonable seizure when officers forced him back into his car and demanded paperwork.
The district court dismissed the suit under Heck v. Humphrey, reasoning that a Section 1983 claim that would imply the invalidity of a conviction is barred; the district judge also suggested other merits-based failures.
The Seventh Circuit (Posner, J.) concluded the alleged unlawful seizure would not invalidate Rollins’s guilty plea because his conviction did not depend on evidence obtained from the challenged seizure.
The Seventh Circuit reversed and remanded for reconsideration of the Fourth Amendment claim without the Heck-bar obstacle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck bars Rollins’s § 1983 claim	Rollins: his claim that officers unlawfully seized him does not imply invalidity of his conviction	Defendants: a ruling for Rollins would undermine his guilty plea and is barred by Heck	Court: Heck does not bar the suit because the seizure ruling would not invalidate the guilty plea
Whether ordering him back into car was a Fourth Amendment seizure	Rollins: ordering him back into car was a seizure that extended detention and can be challenged	Defendants: police action was lawful, or Heck bars challenge	Court: seizure question remains open; district court erred to dismiss on Heck ground alone
Whether illegally obtained evidence would affect the conviction	Rollins: even if seizure unlawful, conviction stands because plea wasn’t based on such evidence	Defendants: conviction might be implicated by challenging police conduct	Court: conviction is independent of the challenged conduct, so civil claim can proceed

Heck v. Humphrey, 512 U.S. 477 (claim barred if success would imply invalidity of conviction)
Wallace v. Kato, 549 U.S. 384 (habeas is the proper vehicle for attacking validity or duration of confinement; clarifies Heck principles)
Okoro v. Callaghan, 324 F.3d 488 (applying Heck in § 1983 context)
Reynolds v. Jamison, 488 F.3d 756 (guilty plea didn’t make false-arrest claim Heck-barred)
Lockett v. Ericson, 656 F.3d 892 (search that didn’t lead to conviction evidence did not bar civil challenge)