Tinsley v. Town of Framingham, 485 Mass. 760

Police stopped Mark Tinsley's car after observing speeding; officers asked him to exit, he refused, and a physical struggle to remove him from the vehicle ensued.
During the struggle inside the vehicle officers used force (grabbing, punches, cutting the seat belt); officers eventually dragged Tinsley out, after which he was beaten, pepper‑sprayed, called a racial slur, and sustained significant injuries.
A jury convicted Tinsley of assault and battery on an officer (Avila), resisting arrest, disorderly conduct, and carrying a dangerous weapon; he was acquitted on a second assault charge.
While criminal charges were pending, Tinsley filed a civil suit under the Massachusetts Civil Rights Act (MCRA) and common‑law torts against the town and the five officers; after his convictions were affirmed, defendants moved for summary judgment.
The SJC adopted Heck’s guiding principle for State‑law claims: a State civil suit may not be used to collaterally attack a State criminal conviction; claims that would necessarily imply invalidity of the convictions are barred, but claims based on facts beyond those necessary to sustain the convictions may proceed.
Applying that rule, the court held Tinsley is collaterally estopped from challenging facts that could have supported his convictions for conduct inside the vehicle, but he may pursue civil claims based on force used after he was removed from the vehicle; false arrest/false imprisonment claims are barred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Heck apply to State civil claims (MCRA and torts)?	Tinsley argued his State civil claims may proceed despite convictions.	Defendants argued Heck bars civil claims that would invalidate convictions.	Court adopts Heck’s guiding principle for State claims: civil suits may not collaterally attack State convictions; plaintiff may proceed only on facts beyond those necessary to sustain convictions.
Do convictions preclude excessive‑force claims about events inside the vehicle?	Tinsley argued force inside vehicle was excessive and violated MCRA/torts.	Defendants argued convictions (assault, resisting) established facts making those claims a collateral attack.	Barred: jury could have relied on inside‑vehicle conduct to convict; Tinsley is collaterally estopped from disputing those facts.
May Tinsley pursue claims based on force after he was removed from the vehicle?	Tinsley contended officers continued excessive force after removal (beatings, slurs).	Defendants argued all force claims are barred by convictions.	Allowed: claims based on post‑removal force do not necessarily invalidate convictions and survive summary judgment; remanded for further proceedings.
Are false arrest / false imprisonment claims viable?	Tinsley claimed detention without probable cause.	Defendants said successful false arrest claim would invalidate convictions.	Barred: a finding of unlawful detention would necessarily imply invalidity of his convictions.

Heck v. Humphrey, 512 U.S. 477 (1994) (civil suit that would necessarily imply the invalidity of a conviction is barred)
Lynch v. Crawford, 483 Mass. 631 (2019) (Mass. court on interplay between civil claims and prior convictions)
Aetna Casualty & Surety Co. v. Niziolek, 395 Mass. 737 (1985) (collateral estoppel from criminal judgments in civil suits)
Thore v. Howe, 466 F.3d 173 (1st Cir. 2006) (Heck analysis applied to excessive‑force claims tied to convictions)
VanGilder v. Baker, 435 F.3d 689 (7th Cir. 2006) (analyze relationship between civil claim and predicate conviction)
Bush v. Strain, 513 F.3d 492 (5th Cir. 2008) (excessive‑force claim not barred if temporally/conceptually distinct from conviction)