Olivier v. City of Brandon, Mississippi

A person previously convicted under a law may use 42 U.S.C. § 1983 to seek a court order blocking that law's future enforcement, even if winning the lawsuit would implicitly show the prior conviction was unconstitutional. Justice Elena Kagan authored the 9-0 majority opinion. The so-called Heck bar—a legal rule from Heck v. Humphrey (1994) that blocks § 1983 suits seeking to undermine a prior criminal conviction—exists for a specific, limited reason: to prevent people from using civil rights lawsuits as a backdoor way to attack their past convictions and obtain release from custody or money damages. Heck targets suits that look backward, forcing courts to relitigate whether a prior conviction was valid. A lawsuit seeking only a forward-looking injunction—as here—does none of those things. It does not ask a court to reverse, erase, or compensate for any past conviction. It creates no competing legal proceedings about past conduct, and it risks no contradictory judgments about what already happened. The concerns that Heck was designed to address simply do not arise. The City of Brandon argued that Heck should still apply because a successful lawsuit would implicitly show that Olivier's prior conviction was wrong—and Heck language bars suits that “necessarily imply the invalidity” of a prior conviction. That reading stretches Heck too far. General language in a judicial opinion must be read in the context of the facts that produced it, and Heck arose from a prisoner seeking money damages tied directly to his allegedly wrongful conviction. Beyond that, the City’s reading produces an absurd result: under its logic, any citizen—even one with no prior conviction—could be blocked from challenging the ordinance, simply because winning would cast doubt on Olivier’s old case. That cannot be right. A purely forward-looking injunction does not collaterally attack a prior conviction; it only prevents future ones, and § 1983 is the proper vehicle for exactly that kind of claim.