Ramirez
Ramirez v. Galaza
Opinion
Lead Opinion
Cowen, J.
California state prisoner Luis Ramirez brought this civil rights action under 42 U.S.C. § 1983 alleging violations of the Due Process and Equal Protection guarantees of the Fourteenth Amendment. Ramirez’s complaint alleged that his constitutional rights were violated by the procedures utilized in a prison disciplinary hearing, and a subsequent administrative appeal. Ramirez also alleged that the conditions of his term of administrative segregation exceeded the normal hardships associated with incarceration. The District Court dismissed the challenge to the disciplinary procedures reasoning that Heck v. Humphrey, 512 U.S. 477 , 114 S.Ct. 2364 , 129 L.Ed.2d 383 (1994), and Edwards v. Balisok, 520 U.S. 641 , 117 S.Ct. 1584 , 137 L.Ed.2d 906 (1997), required Ramirez to invalidate his disciplinary sentence before seeking damages under § 1983. The District Court also dismissed Ramirez’s claims regarding his two-year term of administrative segregation as lacking a protected liberty interest.
We conclude that Ramirez may challenge the conditions of his confinement under § 1983 because his claim, if successful, would not necessarily invalidate a disciplinary action that affects…