Officer’s claim that plaintiff's guilty plea to charge of attempting to resist arrest barred him from asserting that officer violated his rights by gratuitously punching him in the face was effectively reviewable on appeal, and thus court of appeals lacked jurisdiction under collateral order doctrine over officer’s Heck claim on interlocutory appeal of district court’s denial of his motion for summary judgment on qualified immunity grounds.
Claim that officers used excessive force against prisoner in his cell was not barred by Heck because decision that force was excessive would not compel conclusion that disciplinary finding that prisoner engaged in misconduct was invalid.
Heck bar does not apply when criminal charges were dismissed after entry of a plea that was held in abeyance pending the defendant’s compliance with certain conditions; Heck requires an actual conviction, not its functional equivalent.
Plaintiff’s no contest pleas to aggravated flight and assault on a police officer were not inconsistent with her claim that officers used excessive force when they fired at her after she passed them and they were no longer in danger: “a reasonable use of force—such as when an officer is subject to a direct physical threat—may become unreasonable even seconds later when force persists after the threat has passed.