Calvin Williams v. Moberly Correctional Center
Split Score
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Case Summary
Disposition
Affirmed
The Eighth Circuit affirmed the district court’s denial of Calvin Williams’s in-forma-pauperis motion, holding that a prior lawsuit dismissed under Heck v. Humphrey counts as a strike under the PLRA’s three-strikes rule. The court reaffirmed its precedent that a Heck-barred dismissal is a dismissal for failure to state a claim, rejecting Williams’s contrary arguments.
Circuit Split Identified
Legal Issue
Whether a dismissal of a § 1983 action under Heck v. Humphrey counts as a “failure to state a claim” strike for purposes of 28 U.S.C. § 1915(g)’s three-strikes rule in the Prison Litigation Reform Act.
Circuit Positions
Heck dismissal IS a dismissal for failure to state a claim and therefore a PLRA strike
Heck dismissal is NOT automatically a failure to state a claim and does NOT necessarily count as a PLRA strike
Conflict Summary
A majority of circuits hold that a Heck-barred dismissal is a dismissal for failure to state a claim and therefore constitutes a PLRA strike, while a minority treat Heck dismissals as merely premature or otherwise outside the scope of § 1915(g).