Wendell Griffin v. Baltimore Police Department, 2015 U.S. App. LEXIS 18723

Background

In 1982 Griffin was convicted in Maryland state court of murder and sentenced to life; state appeals and post-conviction efforts were unsuccessful and a federal habeas petition filed while incarcerated was denied.
In 2010–2011 Griffin obtained police records via a public-information request and alleged that detectives had withheld Brady material (photo arrays, witness statements, chain-of-custody issues, evidence pointing to another suspect).
A Maryland court conducted an evidentiary hearing in August 2011 and later Griffin’s sentence was modified to time served in May 2012; he was released and probation ended in December 2012.
Griffin then sued under 42 U.S.C. § 1983 seeking damages for alleged Brady violations by police and prosecutors.
The district court dismissed the § 1983 suit under Heck v. Humphrey, reasoning that success on Griffin’s Brady claims would necessarily imply the invalidity of his still-standing conviction; Griffin appealed.
The Fourth Circuit affirmed, holding Heck bars § 1983 damages claims that necessarily imply the invalidity of a conviction unless the conviction has been invalidated or a narrow exception applies (which did not here).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck bars Griffin's § 1983 damages claims based on alleged Brady violations	Griffin: Heck does not apply because he could not practicably seek federal habeas while in custody due to suppressed evidence; Wilson exception should allow his suit now that he is released	Defendants: Heck bars the suit because success would necessarily imply invalidity of the conviction and Griffin’s conviction remains valid	Held: Heck bars the § 1983 Brady claims; Griffin’s convictions have not been invalidated, so his damages suit is premature
Whether the Wilson/Covey “practicable habeas” exception applies	Griffin: He lacked practical access to habeas while incarcerated because exculpatory material was withheld	Defendants: Griffin had ample time (decades) and actually filed federal habeas while incarcerated; he failed to show lack of access	Held: Exception does not apply — Griffin had opportunity and did file habeas; later discovery of evidence while still incarcerated did not show inability to file
Whether Griffin’s release from custody renders Heck inapplicable	Griffin: Being released should allow his § 1983 claim to proceed	Defendants: Heck applies regardless of current custody status; permitting suits after release would circumvent habeas restrictions	Held: Release does not negate Heck; rule prevents waiting until after release to transform § 1983 into collateral post-conviction review
Whether the court decides the merits of the Brady allegations	Griffin: Seeks adjudication of merits in § 1983 action	Defendants: Procedural bar prevents reaching merits now	Held: Court did not reach merits; decision is procedural — Griffin may pursue habeas or state remedies and may refile § 1983 if conviction is invalidated

Key Cases Cited

Heck v. Humphrey, 512 U.S. 477 (prohibits § 1983 claims that would necessarily imply invalidity of conviction unless conviction has been invalidated)
Brady v. Maryland, 373 U.S. 83 (suppression of material, favorable evidence violates due process)
Skinner v. Switzer, 562 U.S. 521 (§ 1983 may support DNA testing claims; distinguishes Brady claims because successful Brady claims necessarily undermine convictions)
Wilson v. Johnson, 535 F.3d 262 (4th Cir.) (narrow exception to Heck where petitioner could not practicably seek habeas while in custody)
Covey v. Assessor of Ohio County, 777 F.3d 186 (4th Cir.) (applies Wilson framework; exception limited to those who lacked practical access to habeas)
Preiser v. Rodriguez, 411 U.S. 475 (habeas is the exclusive federal remedy for state prisoners seeking release)
Nelson v. Campbell, 541 U.S. 637 (explains the favorable-termination requirement under Heck)
Harrington v. Richter, 562 U.S. 86 (discusses habeas intrusion on state sovereignty and deference to state proceedings)