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Huang v. Johnson

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Argued: May 2, 2000

Appeal from an adverse grant of summary judgment by the United States District Court for the Southern District of New York (Richard C. Casey, Judge). Appellant alleges that appellees violated her son’s Fourth and Fourteenth Amendment rights by imprisoning him falsely and without due process. We conclude that transfer from an “Evening Reporting Center” program to a more restrictive residential program does not implicate due process concerns. We also conclude that the limitation on Section 1983 claims set forth in Heck v. Humphrey, 512 U.S. 477 (1994), does not bar an action for incarceration beyond a statutory release date brought after the plaintiff is released.

Michelle Huang appeals from Judge Casey’s adverse grant of summary judgment in this 42 U.S.C. � 1983 action brought on behalf of her infant son, Raymond Yu. See Huang v. Johnson, No. 98 Civ. 5231, 1999 WL 760633 (S.D.N.Y. Sept. 27, 1999). Huang argues that Yu’s Fourteenth and Fourth Amendment rights were violated when appellees — all New York correctional officials — imprisoned him without due process and falsely. Specifically, Huang contends that: (i) Yu had a right to a hearing before appellees placed him in a residential facility instead of the less restrictive “day placement” program to which he had previously been assigned; and (ii) appellees illegally retained Yu in custody for eighty-three days by failing to credit to his juvenile sentence time served while in pre-trial incarceration at Riker’s Island. Appellees assert that all of Huang’s claims are barred by the Eleventh Amendment. With regard to (ii), there is a threshold issue as to whether appellant’s Section 1983 claims are barred by Heck v. Humphrey, 512 U.S. 477 (1994). Heck bars Section 1983 damages actions in which a judgment in the plaintiff’s favor would necessarily imply the invalidity of a conviction or sentence where such conviction or sentence has not yet been invalidated, reversed on direct appeal, or called into question by the issuance of a writ of habeas corpus.

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