Calvin Williams v. Moberly Correctional Center

Circuit 8Oct 8, 2026

Split Score

SplitScore: 74/100

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.

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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

Circuit 3Circuit 4Circuit 5Circuit 8(this circuit)Circuit 10DC Circuit

Heck dismissal IS a dismissal for failure to state a claim and therefore a PLRA strike

Circuit 2Circuit 7Circuit 9

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).

Parties & Counsel

Parties

Appellant:Calvin J. Williams
Appellee:Moberly Correctional Center, Marcus Groza, and Mike Hanline