Olivier v. City of Brandon · ¶10

The District Court agreed with the City's understanding of Heck, and the Court of Appeals for the Fifth Circuit affirmed on the same reasoning. If Olivier's § 1983 suit succeeded, the District Court reasoned, the judgment would “undermine his Municipal Court conviction.” 2022 WL 15047414, *11 (SD Miss., Sept. 23, 2022). And so the suit was categorically barred under Heck. Similarly, the Fifth Circuit viewed Heck as precluding any § 1983 claim that, if successful, would “necessarily imply the invalidity of the plaintiff 's criminal conviction.” 2023 WL 5500223, *1 (Aug. 25, 2023); see Heck, 512 U. S., at 487 (using near-identical language). Olivier's claim, the court maintained, was of that sort: If he showed that the city ordinance violated the First Amendment, he also would show that his prior conviction should not have happened. And that fact, the court concluded, was dispositive. It…

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