Fourth Circuit Reverses S.C. Dist. Judge in Extradition Suit

In Young v. Nikols, a Fourth Circuit panel examined a dismissal of a prisoner's complaint brought under 42 U.S.C. section 1983 which alleged that his extradition rights had been violated. Because the prisoner could not establish that his underlying criminal judgment had been invalidated, the district court held that his complaint is barred by Heck v. Humphrey, 512 U.S. 477 (1994).

The Fourth Circuit reverses, holding that Heck only bars a prisoner's section 1983 claim if the relief sought necessarily implies the invalidity of his criminal judgment. Mr. Young's section 1983 damages claim for illegal extradition does not imply that his criminal judgment is invalid; therefore, Heck did not require the dismissal of the complaint.