In the 1993 U.S. Supreme Court case, Roy Heck v. James Humphrey et al., Roy Heck, a prisoner in Indiana, filed a lawsuit against prison officials for allegedly violating his constitutional rights by using excessive force and denying him due process during disciplinary proceedings that resulted in loss of good-time credits. The court ruled that Heck's claim was not actionable under Section 1983 because it implied the invalidity of his conviction or sentence which had not been reversed on appeal or declared invalid by state tribunal or federal habeas corpus proceeding. This ruling established what is now known as "Heck's rule," stating that if a judgment for damages necessarily requires questioning the legality of conviction or confinement, then no claim can be made unless said conviction has been invalidated.

In the dissenting opinion for Roy Heck v. James Humphrey et al., Justice Souter argued that a prisoner should be allowed to bring a §1983 claim before his conviction or sentence has been invalidated, as long as he is not challenging the fact of his confinement. He believed that this approach would better serve the purpose of §1983 by providing an avenue for prisoners to seek redress for constitutional violations without having to first navigate through complex habeas corpus proceedings. Furthermore, he disagreed with the majority's reliance on common law principles in interpreting §1983 and instead advocated for an interpretation based on Congressional intent and statutory language. Finally, Justice Souter expressed concern about potential unfairness resulting from requiring prisoners to exhaust their habeas remedies before bringing a §1983 claim, especially given the limited resources available to many inmates.