Haring v. Prosise

Defendant pleaded guilty to manufacturing a controlled substance. Subsequent to this, Defendant filed a claim for damages under 42 U.S.C. § 1983 against the police, alleging that his Fourth Amendment rights were violated by the police during their search of his apartment. The district court granted summary judgment for the officer, finding that Defendant’s guilty plea barred his claim. The court reasoned that Defendant’s failure to assert his claim in state court constituted a waiver of that right, precluding its assertion in a later federal action. The district court also held that Defendant’s guilty plea constituted an implied admission that the search of his apartment was legal. The circuit court reversed and remanded. The Supreme Court affirmed, finding that collateral estoppel did not apply to the present case under Virginia law. The Court based this on three findings. First, the legality of the search was not actually litigated in the case. Second, the criminal proceedings did not actually decide against Defendant on any issue on which he must prevail to establish his claim. Finally, none of the issues in the § 1983 action could have been necessarily determined in the criminal proceeding. The Court similarly found that a special rule preventing these suits was not appropriate. The Court therefore affirmed the appeals court.

“We conclude that respondent’s conviction in state court does not preclude him from now seeking to recover damages under 42 U.S.C. § 1983 for an alleged Fourth Amendment violation that was never considered in the state proceedings.” p.323