Jeffrey Goodwin v. Margarette Ghee

Citations: 330 F.3d 446; 2003 U.S. App. LEXIS 9549; 2003 WL 21157947Docket: 00-3339

Court: Court of Appeals for the Sixth Circuit; May 19, 2003; Federal Appellate Court

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The United States Court of Appeals for the Sixth Circuit reviewed the case of Jeffrey Goodwin against Margarette Ghee, with an en banc court equally divided on the judgment. Five judges favored affirming the district court's ruling, while five supported reversal, leading to the affirmation of the lower court's decision based on precedent from Stupak-Thrall v. United States.

Goodwin, while incarcerated, criticized the Ohio Parole Board in a letter published in the Cleveland Call and Post, alleging discriminatory practices. During his first parole hearing in May 1998, Parole Board member Larry Matthews allegedly threatened Goodwin with an excessive sentence as retaliation for his public criticism and assigned him a conviction-offense level of seven, which delayed his eligibility for release compared to the level of four he should have received.

After filing for reconsideration, a majority of the Parole Board voted to rescind the initial finding, and a subsequent hearing in April 1999 determined Goodwin's conviction-offense level should be four. However, this decision did not take into account an armed robbery charge. Following this hearing, Matthews reportedly indicated that the outcome would change when reviewed by the full Parole Board. In June 1999, the full Parole Board reassessed Goodwin's case and reinstated the conviction-offense level of seven, effectively extending his imprisonment until at least April 2005.

Goodwin's complaint alleges retaliation by the Ohio Parole Board against his First Amendment rights under 42 U.S.C. § 1983. The legal standard established by the Supreme Court in Heck v. Humphrey requires that for a § 1983 claim to be valid, a favorable judgment for the plaintiff must not imply the invalidity of their conviction or sentence. The district court granted summary judgment for the state, concluding that a ruling in Goodwin's favor would imply the invalidity of the Board's decision to deny his parole. Goodwin's claim is closely related to Edwards v. Balisok, where the Supreme Court determined that allegations against prison procedures could imply the invalidity of a conviction. Goodwin's assertion involves intentional misconduct by a hearing officer, echoing the reasoning in Edwards that such claims cannot stand if they suggest the invalidity of prior decisions. A dissenting opinion from Judge Cole contends that Goodwin's challenge does not directly attack the conviction or confinement duration, arguing that he seeks only a new hearing and thus supports the appropriateness of a § 1983 lawsuit.

Defendants argued that if Goodwin were to prevail on his § 1983 claim, he would be entitled to immediate release due to a reduction in his conviction offense level from seven to four. However, this assertion is incorrect. Success on his § 1983 claim would only grant Goodwin access to the parole board, not a guarantee of parole or a shorter sentence. He would receive a new hearing, akin to previous reconsiderations, where the Parole Board would have significant discretion under Ohio law to assess his conviction offense level and potential release date. While a lower offense level could be assigned, there is also a possibility for the level to remain the same or increase, depending on various factors, including Goodwin's conduct in prison and any new recommendations from rehabilitation staff. Consequently, because Goodwin seeks a new hearing where the Parole Board will exercise its discretion, his § 1983 claim is not precluded by the ruling in Heck v. Humphrey.