Heck v. Humphrey’s Empirical Analysis
1994
Citation profile
2,117 federal appellate · 731 district · 410 state decisions
How this case has been cited
Cited by 12,013 later decisions (62 by the Supreme Court) — most recently May 2026 · most notably Spencer v. Kemna (1998), Edwards v. Balisok (1997)
2,117 federal appellate · 731 district · 410 state decisions — followed in 40 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedHeck v. Humphrey (from Seventh Circuit Court of Appeals)
Relationships
Relies on Monell v. Department of Social Services of City of New York · Anderson v. Creighton · Wolff v. McDonnell · Colorado River Water Conservation District v. United States
Cited together with Edwards v. Balisok · Preiser v. Rodriguez · Spencer v. Kemna · Monell v. Department of Social Services of City of New York · Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 12,013 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]n order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court’s issuance of a writ of habeas corpus, 28 U.S.C. § 2254 . A claim for damages bearing that relationship to a conviction or sentence that has not been so invalidated is not cognizable under § 1983.”
623 later decisions quote this exact passage“For example, a suit for damages attributable to an allegedly unreasonable search may lie even if the challenged search produced evidence that was introduced in a state criminal trial resulting in the § 1983 plaintiffs still-outstanding conviction. Because of doctrines like independent source and inevitable discovery, and especially harmless error, such a § 1983 action, even if successful, would not necessarily imply that the plaintiffs conviction was unlawful.”
58 later decisions quote this exact passage · from the majority“a § 1983 cause of action for damages attributable to an unconstitutional conviction or sentence does not accrue until the conviction or sentence has been invalidated.”
26 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.