February 19, 2020

In this column, Jenner & Block Partner Michael T. Brody explains that the Seventh Circuit recently applied the US Supreme Court’s decision in Heck v. Humphrey in the case of Savory v. Cannon.  In Savory, the Seventh Circuit held that Mr. Savory’s civil rights lawsuit was permitted – it accrued at the time of his gubernatorial pardon, not an earlier event such as his release from prison or commutation of his sentence.  “The Seventh Circuit has now conclusively ruled for cases subject to the Heck bar, the cause of action accrues upon a favorable termination of the underlying criminal case, not just release from prison,” Mike observes.  He gives the background of Savory and examines the Seventh Circuit’s reasoning.