The U.S. Supreme Court's decision in Heck v. Humphrey does not bar a released federal prisoner's false imprisonment claims under the Federal Tort Claims Act (FTCA), the U.S. Court of Appeals for the Eleventh Circuit held on July 6, 2010.

Anthony Morrow sued the United States under the FTCA after his release from federal prison claiming that his incarceration had been prolonged unlawfully by ten extra days due to a miscalculation of his sentence.

The district court dismissed Morrow's suit, holding that Heck precluded relief. Heck held that a prisoner could not pursue monetary damages under 42 U.S.C. § 1983 if a favorable judgment on those claims would necessarily imply the invalidity of the prisoner's conviction or sentence. Although decided in the § 1983 context, Heck has been held to apply to FTCA claims as well.

While Heck may apply to FTCA claims, the Eleventh Circuit held that Heck did not apply in Morrow's case because (1) Morrow was no longer in custody and (2) a favorable judgment would "in no way impl[y] the invalidity of his conviction or of the sentence imposed by his conviction," the court wrote.

The court seemed to intimate, though, that its decision might have been different if Morrow would have had sufficient time to seek habeas relief prior to his release. Morrow alleged that he did not find out about the error in his sentence calculation until two days before his release.

The judgment of the district court was accordingly reversed and the case was remanded for further proceedings. See: Morrow v. Federal Bureau of Prisons, 610 F.3d 1271 (11th Cir. 2010).

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