Bronowicz v. County of Allegheny, No. 13-4497 (3d Cir. 2015)
Annotate this CaseIn 2000, Bronowicz was charged with crimes ranging from terroristic threats to driving under the influence. He entered a negotiated plea, served his term of imprisonment, and was released. A complicated sequence of probation revocation and sentencing proceedings allegedly had the cumulative effect of unlawfully imposing additional penalties for criminal judgments that had already been satisfied. Bronowicz successfully appealed his additional prison sentence in state court and then filed a federal suit, seeking damages for wrongful incarceration under 42 U.S.C. 1983. The district court dismissed his claims as barred by the 1994 Supreme Court decision, Heck v. Humphrey. The Third Circuit reversed in part, holding that an order from the Superior Court of Pennsylvania vacating a sentence imposed by a court of common pleas constitutes a favorable termination of the proceedings against a plaintiff within the meaning of Heck v. Humphrey, notwithstanding the fact that the order failed expressly to address the inmate’s specific legal challenges to the sentence, so that any section 1983 claims stemming from the invalidated sentence are not barred by Heck.
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