411 U.S. 475, 497
The three respondents were state prisoners serving sentences in New York correctional facilities.1 Rodriguez had been convicted of perjury and attempted larceny and was serving an indeterminate term of from one and one-half to four years.2 Katzoff had been convicted of possession of a dangerous weapon and was serving a sentence of one to three years.3 Kritsky had been convicted of armed robbery and was serving a sentence of fifteen to eighteen years.4
Each respondent had elected to participate in the state's conditional-release program, under which a prisoner could earn up to ten days per month of good-behavior-time credit toward reduction of the maximum term of his sentence.5 Rodriguez was charged in two disciplinary action reports with possession of contraband material in his cell and lost 120 days of earned good-conduct-time credits.6 Katzoff was charged with making derogatory comments about prison officials in his diary and ultimately lost 50 days of good-behavior-time credits.7 Kritsky was charged with being a leader in a prison-wide protest demonstration and lost 590 days of good-conduct-time credits.8
Each respondent filed a complaint pursuant to 42 U.S.C. § 1983 combined with a petition for a writ of habeas corpus in the United States District Court for the Northern District of New York.9 The district courts held that the actions were properly brought under the Civil Rights Act.10 They found that the prisoners had been deprived of due process in the disciplinary proceedings.11 The courts ordered restoration of the good-conduct-time credits, which entitled each prisoner to immediate release from prison.12
The Court of Appeals for the Second Circuit initially reversed the district court judgments in the cases of Rodriguez and Katzoff.13 After rehearing the three cases en banc the court affirmed the judgments of the district courts in all three cases.14 The Supreme Court granted certiorari to consider the relationship between actions under the Civil Rights Act and petitions for habeas corpus in this context.15
Whether state prisoners deprived of good-conduct-time credits by prison disciplinary proceedings may seek injunctive relief restoring those credits through an action under 42 U.S.C. § 1983 without first exhausting available state remedies?16
When a state prisoner challenges the fact or duration of his physical imprisonment, and seeks a determination that he is entitled to immediate release or a speedier release, his sole federal remedy is a writ of habeas corpus.17 This requires exhaustion of available state remedies under 28 U.S.C. § 2254(b) before a federal court may entertain the claim.18 Although 42 U.S.C. § 1983 provides a general remedy for constitutional violations, the specific habeas corpus statute controls in this context to preserve federal-state comity and the congressional policy embodied in the exhaustion requirement.19
No. The respondents Rodriguez, Katzoff, and Kritsky each sought restoration of good-conduct-time credits through § 1983 actions, which would result in their immediate release from prison.20 Because their claims directly attacked the duration of their physical confinement, the claims fell within the core of habeas corpus.21 The district courts and court of appeals treated the actions as cognizable under § 1983 without exhaustion.22 Under the rule, such challenges must be brought as habeas petitions after first seeking relief in state courts.23
The availability of an adequate state remedy under New York Civil Rights Law § 79-c further supports requiring exhaustion before federal intervention.24
State prisoners seeking restoration of good-conduct-time credits that would affect the duration of their confinement may not proceed under 42 U.S.C. § 1983 without exhausting state remedies; their exclusive federal remedy is habeas corpus.25
Related opinions on this issue
Joined by Justice Douglas And Justice Marshall
Justice Brennan dissented on the ground that the majority's newly drawn distinction between challenges to the fact or duration of confinement and challenges to conditions of confinement was both analytically unsound and unworkable in practice.26 He maintained that Wilwording v. Swenson controlled the cases.27 State prisoners should remain free to bring actions for injunctive relief under § 1983 without any exhaustion requirement.28
The absence of an exhaustion rule is an integral feature of the Civil Rights Act designed to provide a federal forum for constitutional claims.29 Brennan concluded that the majority's approach would only complicate prison-conditions litigation.30 It would create perverse incentives for prison officials.31
It would also undermine the purposes of both the habeas corpus exhaustion requirement and the Civil Rights Act.32