In the 1996 case of Gary Edwards and Tana Wood v. Jerry B. Balisok, the U.S Supreme Court ruled that a state prisoner's claim for damages, which implies the invalidity of his punishment or confinement without due process, is not cognizable under 42 U.S.C §1983 if judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence unless it has been previously invalidated. The respondent Jerry B. Balisok was a Washington State inmate who claimed that he had been deprived of good-time credits without due process as part of disciplinary proceedings against him by prison officials (petitioners). He sought declaratory relief and monetary damages but did not seek restoration to good standing or any other speedier release from custody than what might result from successful administrative review. The court held that such claims are not actionable because they challenge "the fact or duration" rather than "conditions" of confinement.

In the dissenting opinion for Gary Edwards and Tana Wood v. Jerry B. Balisok, Justice Scalia disagreed with the majority's view that a claim for declaratory relief and money damages, brought by a state prisoner who alleged that procedures used in his disciplinary proceedings violated due process, was not cognizable under 42 U.S.C § 1983 because it necessarily implied the invalidity of punishment imposed. He argued that this interpretation expanded too far on previous rulings which barred claims only when they directly sought to overturn a conviction or sentence. In his view, procedural errors could exist without implying an unlawful detention; thus such claims should be allowed even if successful litigation wouldn't immediately lead to release from prison or shortening of sentence length.