Lund v. Datzman

Whether the Heck v. Humphrey bar on suits under 42 U.S.C. § 1983 that "would necessarily imply the invalidity" of a conviction that has not been set aside is categorically inapplicable when a convicted individual brings a Fourth Amendment claim seeking damages for an unreasonable search or seizure but not for the conviction obtained using fruits of the constitutional violation, regardless of whether the factual record reveals a particular exclusionary-rule exception or harmless-error theory that could potentially sustain the conviction"s validity despite the violation.