Fernandez v. United States · ¶113

Worse still, on its way to announcing that “[a] prisoner who collaterally attacks the validity of his conviction must proceed through” habeas only, the majority fails to define with any precision what it means for a prisoner to “collaterally attac[k] the validity of his conviction.” Ante, at 415. Its inability to do so is understandable, since delineating the bounds of such “collateral attacks” is notoriously difficult. Cf. W. Baude, J. Goldsmith, J. Manning, J. Pfander, & A. Tyler, Hart and Wechsler's The Federal Courts and the Federal System 1687 (8th ed. 2025) (Hart & Wechsler) (discussing the difficulty of determining when, under the Preiser line of cases, a successful §1983 action necessarily implies “the invalidity of the plaintiff's conviction”).

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