Sampson v. Garrett

Sampson is serving a life sentence in a Michigan prison. He sued Wayne County, state court officials, and private attorneys under 42 U.S.C. 1983, alleging they conspired to deprive him of trial transcripts, exhibits, and other records to frustrate his constitutional right to access the court. The district court dismissed Sampson’s pro se complaint, concluding that several defendants are immune from suit or are not state actors and that the Supreme Court’s 1994 holding, Heck v. Humphrey, bars his access-to-the-court claim because its success “would necessarily imply the invalidity of his conviction or sentence.” The Sixth Circuit affirmed. Heck was intended to channel what amount to unlawful-confinement claims to the place they belong: habeas corpus; the reasoning applies to an access-to-the-court claim alleging state interference with a direct criminal appeal. Sampson could prevail on his claim only if he showed that the information he sought could make a difference in a nonfrivolous challenge to his convictions; he could win only if he implied the invalidity of his underlying judgment. A favorable judgment on Sampson’s access-to-the-court claim would necessarily bear on the validity of his underlying judgment, because that is exactly what he says the defendants kept him from contesting fairly. View "Sampson v. Garrett" on Justia Law