Case Explained: BROWN V. CITY AND COUNTY OF SAN FRANCISCO, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-29 Docket: 3:25-cv-06667-WHO The Ninth Circuit affirmed the district court’s dismissal of Gregory L. Brown’s pro se 42 U.S.C. § 1983 action alleging constitutional violations related to his arrest, conviction, and sentencing. The court held that the dismissal was proper under *Heck v. Humphrey*, 512 U.S. 477 (1994), because a judgment in Brown’s favor would necessarily imply the invalidity of his state conviction or sentence, and he failed to demonstrate that his conviction or sentence had already been invalidated. Additionally, the court ruled that the district court was required to screen the complaint under 28 U.S.C. § 1915A regardless of whether Brown paid the filing fee, as the statute mandates screening for prisoner civil actions seeking redress from governmental entities. The judgment is affirmed, leaving the dismissal in place and barring the plaintiff’s claims until his underlying conviction or sentence is invalidated. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.