Haring v. Prosise
United States Supreme Court
462 U.S. 306 (1983)
- Written by Noah Lewis, JD
Facts
John Franklin Prosise (plaintiff) pleaded guilty to manufacturing phencyclidine, a controlled substance. After officers testified about finding devices and chemicals used to manufacture phencyclidine in his apartment, Prosise pleaded guilty pursuant to a plea agreement and was sentenced to 25 years in prison. While incarcerated, Prosise brought a pro se 42 U.S.C. § 1983 damages claim against Gilbert Haring and other officers (the officers) (defendants) alleging they had, in violation of the Fourth Amendment, unlawfully searched his apartment prior to obtaining a search warrant and exceeded the scope of the warrant they did obtain. The district court granted summary judgment for defendants on the ground that Prosise’s guilty plea barred his § 1983 claim. The court of appeals reversed in part and remanded for further proceedings, finding that criminal judgments have no preclusive effect in subsequent civil litigation, especially in the absence of a trial. The court of appeals denied rehearing and rehearing en banc. The Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Marshall, J.)
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