Timothy Sampson v. Cathy Garrett, 917 F.3d 880

Timothy Sampson, a Michigan prisoner serving life, sued Wayne County, state-court officials, and private attorneys under 42 U.S.C. § 1983, alleging a conspiracy to deprive him of trial transcripts, exhibits, and records that frustrated his right of access to the courts.
Sampson alleged the defendants prevented him from using those materials in his direct criminal appeal.
The district court dismissed the pro se complaint for failure to state a claim, concluding some defendants were immune or not state actors and that Heck v. Humphrey barred Sampson’s access-to-court claim.
The Sixth Circuit reviewed de novo whether Heck bars an access-to-court claim premised on interference with a direct criminal appeal.
The court focused on Christopher v. Harbury’s rule that a successful access claim requires showing the underlying claim was nonfrivolous and that being denied the materials caused an injury to pursuing that claim.
The Sixth Circuit affirmed dismissal, holding success on Sampson’s access claim would necessarily imply invalidity of his conviction, and ordered dismissal without prejudice as to access and state-law claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck bars a § 1983 access-to-court claim based on denial of trial materials for a direct appeal	Sampson: denial of transcripts and records injured his access rights and entitles him to damages	Defendants: allowing the claim would imply invalidity of the conviction and is barred by Heck	Held: Heck bars the access claim because success would necessarily imply invalidity of the underlying judgment
Whether access claim requires showing the underlying claim was nonfrivolous	Sampson: need only show denial frustrated his ability to pursue appeal	Defendants: plaintiff must show the withheld materials could have made a nonfrivolous difference	Held: Court adopts Christopher v. Harbury standard that plaintiff must show the withheld information could make a nonfrivolous challenge
Whether other access or civil claims survive pleading standards	Sampson: broadly alleged multiple access deprivations against many defendants	Defendants: allegations are conclusory and fail to link specific acts to defendants	Held: Other access-related and non-Heck claims fail plausibility and insufficiently plead facts or defendant-specific conduct
Proper disposition/form of dismissal	Sampson: sought damages; implied need for merits consideration	District: dismissed with prejudice	Held: Affirm dismissal on Heck grounds but order that access and state-law claims be dismissed without prejudice

Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claim that would imply invalidity of conviction is barred until conviction is invalidated)
Christopher v. Harbury, 536 U.S. 403 (2002) (right of access claim requires showing underlying claim is nonfrivolous and was impeded)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (Heck inapplicability depends on whether relief would imply invalidity of conviction)
Skinner v. Switzer, 562 U.S. 521 (2011) (explains Wilkinson’s rationale regarding when Heck does not bar claims)
Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (pro se pleadings reviewed under applicable standards)
Lanman v. Hinson, 529 F.3d 673 (6th Cir. 2008) (plaintiff must link allegations to material facts and identify defendant-specific conduct)