Huang v. Johnson

251 F.3d 65 (2nd Cir. 2001) ; Clearinghouse Number: 53800

Description

Second Circuit Holds That Juvenile May Bring False Imprisonment Claim Under Section 1983 Because He Lacks Habeas Corpus Remedy

Abstract

The Second Circuit held that the U.S. Supreme Court’s decision in Heck v. Humphrey, 512 U.S. 477 (1994), did not bar plaintiff-appellant’s Section 1983 action claiming false imprisonment. Plaintiff-appellant’s minor son was adjudicated delinquent and sentenced to a day program. When he failed to report following an arrest and detention for attempted murder, defendant-appellees transferred him to a more restrictive program and added the time he spent in custody on the second charge to his original juvenile sentence. After completing the extended sentence, he pled guilty to the second charge. Plaintiff-appellant brought this Section 1983 action, alleging her son had a right to a pretransfer hearing and that his time in custody on the second charge should have been credited to his juvenile sentence. The district court denied both claims. Regarding false imprisonment, it relied on a New York statute prohibiting credit for time served on an unrelated arrest resulting in conviction. The district court also held that the Eleventh Amendment barred plaintiff’s damages claim. The Second Circuit found that Heck, which requires a Section 1983 plaintiff to show that either the conviction was overturned or a writ of habeas corpus was issued, did not bar a false imprisonment claim where plaintiff was released and habeas relief was not available. Declining to interpret the state statute at issue, the Second Circuit certified to the New York Court of Appeals the question of whether the release date had been properly calculated. It held that transfer to the more restrictive placement did not implicate due process concerns and found no bar to damages claims against defendant-appellees sued in their individual capacities; such a ruling “would transfer Eleventh Amendment immunity to such individuals.”

Additional Information

Attorney Information
Docket Date
2001-05-17 00:00:00+00:00

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