Haring v. Prosise
Annotate this Case
462 U.S. 306 (1983)
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U.S. Supreme Court
Haring v. Prosise, 462 U.S. 306 (1983)
Haring v. Prosise
Argued April 20, 1983
Decided June 13, 1983
462 U.S. 306
A Virginia trial court accepted respondent's plea of guilty to a charge of manufacturing a controlled substance. At the hearing at which respondent pleaded guilty, one of petitioner police officers gave a brief account of the search of respondent's apartment that led to the discovery of material typically used in manufacturing the controlled substance. Thereafter, respondent brought a damages action under 42 U.S.C.1983 in Federal District Court against petitioners, officers who participated in the search of his apartment, alleging that his Fourth Amendment rights had been violated. The District Court granted summary judgment for petitioners on the ground that respondent's guilty plea to the criminal charge barred his § 1983 claim. The Court of Appeals reversed in pertinent part and remanded.
1. The § 1983 action is not barred on the asserted ground that, under principles of collateral estoppel generally applied by the Virginia courts, respondent's conviction would bar his subsequent civil challenge to police conduct, and that a federal court must therefore give the state conviction the same effect under 28 U.S.C. § 1738, which generally requires federal courts to give preclusive effect to state court judgments if the courts of the State from which the judgments emerged would do so. Under collateral estoppel rules applied by Virginia courts, unless an issue was actually litigated and determined in the prior judicial proceeding, it will not be treated as final for purposes of the later action. Furthermore, under Virginia law, collateral estoppel precludes litigation of only those issues necessary to support the judgment entered in the first action. Thus, the collateral estoppel doctrine would not be invoked in this case by Virginia courts for at least three reasons. First, the legality of the search of respondent's apartment was not litigated in the criminal proceedings. Second, the criminal proceedings did not decide against respondent any issue on which he must prevail in order to establish his 1983 claim, the only question determined by the guilty plea being whether respondent unlawfully engaged in the manufacture of a controlled substance. This question is irrelevant to the legality of the search or to respondent's right to compensation from state officials under
§ 1983. Finally, none of the issues in the § 1983 action could have been "necessarily" determined in the criminal proceeding. A determination as to whether or not the search of respondent's apartment was legal would have been entirely irrelevant in the context of the guilty plea proceeding. Pp. 462 U. S. 312-317.
2. Nor is litigation of respondent's § 1983 damages claim barred on the asserted ground that, because he had an opportunity to raise his Fourth Amendment claim in the criminal prosecution, by pleading guilty, he should be deemed to have either admitted the legality of the search or waived any Fourth Amendment claim. The guilty plea in no way constituted an admission that the search of his apartment was proper under the Fourth Amendment. It may not be assumed that a guilty plea is based on a defendant's determination that he would be unable to prevail on a motion to suppress evidence, since a decision to plead guilty may have any number of other motivations. Cf. Tollett v. Henderson, 411 U. S. 258, 411 U. S. 263, 411 U. S. 268. Similarly, although a guilty plea results in the defendant's loss of any meaningful opportunity he might otherwise have had in the criminal proceeding to challenge the admissibility of evidence obtained in violation of the Fourth Amendment, it does not follow that a guilty plea is a "waiver" of antecedent Fourth Amendment claims that may be given effect outside the confines of the criminal proceeding. And while a Fourth Amendment claim ordinarily may not be raised in a habeas corpus proceeding following a guilty plea, that conclusion does not rest on any notion of waiver, but rests on the fact that the claim is irrelevant to the constitutional validity of the conviction. Thus, the justifications for denying habeas review of Fourth Amendment claims following a guilty plea are inapplicable to an action under § 1983. Adoption of a rule of preclusion in this case would threaten important interests in preserving federal courts as an available forum for the vindication of constitutional rights. Pp. 462 U. S. 317-323.
667 F.2d 1133, affirmed.
MARSHALL, J., delivered the opinion for a unanimous Court.