After the preacher was cited for sharing his faith in a Mississippi public park, the Court cleared the way for him to challenge the city’s restrictive ordinance in federal court—affirming that people can seek forward-looking constitutional protections even after a prior conviction.

(ANALYSIS) The Supreme Court announced a major decision last week in what seems like a quintessential religious freedom case: A Christian preacher charged with violating a city ordinance for sharing his faith in a public park. But outrageous as it may have been, the preacher’s arrest was not actually at the heart of this case.

After pleading no contest to violating Brandon, Mississippi’s ordinance and paying a fine, Gabriel Olivier challenged the ordinance in federal district court under the First and Fourteenth Amendments, and asked for an order blocking the city from enforcing it against him in the future. Olivier brought those claims by way of 28 U.S.C. Sec. 1983, a federal statute that allows people to sue state actors for violations of the U.S. Constitution.

The district court dismissed Olivier’s suit on the basis of Heck v. Humphrey, a 1994 Supreme Court case holding that prisoners cannot maintain suits under Sec. 1983 that would necessarily invalidate their convictions.

Under the Heck rule, prisoners must first have those convictions overturned through the federal habeas corpus statute. The purpose of this rule is to stop prisoners from using Sec. 1983 as a means of circumventing the strict limits on habeas corpus.

The district court reasoned that if Olivier prevailed in his Sec. 1983 claim that the city’s ordinance was unconstitutional, it would necessarily imply that his conviction for violating it was also unconstitutional. And for the district court, that meant that Olivier would have to challenge the constitutionality of the statute by satisfying the rigorous requirements of a writ of habeas corpus application, not through Sec. 1983.

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