Olivier v. City of Brandon · ¶20

In two later decisions, though, the Court drew a line between Heck-type claims and those seeking forward-looking relief. In Edwards v. Balisok, 520 U. S. 641 (1997), a state prisoner alleged that procedures used in a disciplinary hearing—which had deprived him of good-time credits and thus lengthened his sentence—violated his Fourteenth Amendment due process rights. He sought money damages for the alleged past violation; he also sought an injunction requiring prison officials to adopt new procedures, so as to “prevent future violations.” Id., at 643. The Court made short work of the claim for damages. As in Heck, the Court reasoned, the prisoner could not obtain damages without demonstrating “the invalidity of the punishment imposed” on him (i. e., the loss of his good-time credits), and thus impinging on habeas. 520 U. S., at 648. But the claim for “prospective injunctive relief”—the…

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