Robert H. Young v. Phyllis Kenny, Thomas Manning, Henry Rose

Robert Young, a Washington state prisoner, filed a complaint for damages pursuant to 42 U.S.C. § 1983 (1982), claiming that state officials had unconstitutionally failed to apply good-time credits to his prison sentence. The district court dismissed his complaint; we modify the district court’s order to stay rather than dismiss the claim.

1. Where a state prisoner challenges the fact or duration of his confinement, his sole federal remedy is a writ of habeas corpus. Preiser v. Rodriguez, 411 U.S. 475, 489-90, 500 , 93 S.Ct. 1827, 1836, 1841 , 36 L.Ed.2d 439 (1973). This is largely because, while a habeas petitioner must exhaust state remedies, Rose v. Lundy, 455 U.S. 509, 515 , 102 S.Ct. 1198, 1201 , 71 L.Ed.2d 379 (1982), a section 1983 plaintiff need not. Ellis v. Dyson, 421 U.S. 426, 432-33 , 95 S.Ct. 1691, 1695 , 44 L.Ed.2d 274 (1975). If habeas were not the exclusive federal method for challenging the length of a state prison sentence, the exhaustion requirement could be easily circumvented: A prevailing section 1983 plaintiff would obtain a federal court’s ruling that his sentence is too long, a judgment that would preclude relitigation of the issue in a subsequent state…