The New Jersey Supreme Court issued a unanimous decision extending federal civil rights precedent to state law claims, clarifying when individuals can file lawsuits challenging government actions that relate to ongoing criminal proceedings.
In *C.A.L. v. State*, decided Jan. 27, the court held that the favorable-termination rule from *Heck v. Humphrey* applies to claims brought under both the New Jersey Civil Rights Act and the New Jersey Tort Claims Act. The federal precedent requires that civil rights claims that would undermine the validity of a criminal proceeding cannot be filed until that proceeding has been resolved in the plaintiff's favor.
The case centers on C.A.L., who was convicted in 2005 of endangering the welfare of a child and placed on Parole Supervision for Life. The New Jersey State Parole Board imposed two special conditions on her parole: a complete ban on accessing social media platforms and a prohibition on viewing or possessing pornography.
In February 2018, C.A.L. was arrested on a parole warrant for allegedly violating both conditions. She challenged the constitutionality of these restrictions, arguing they violated her First Amendment rights. The Parole Board conducted a hearing and found clear and convincing evidence that C.A.L. had violated both conditions. As a result, the board revoked her Parole Supervision for Life status and ordered her to remain incarcerated for 12 months.
C.A.L. appealed the revocation to the Appellate Division. While her appeal was pending, the appellate court decided *K.G. v. State Parole Board* in 2019, which established that internet access restrictions for parolees must be reasonably tailored to the individual offender. This precedent proved favorable to C.A.L.'s case.
Following the *K.G.* decision, the Parole Board reconsidered C.A.L.'s situation. On Feb. 6, 2020, the board vacated its 2018 revocation of C.A.L.'s Parole Supervision for Life. The board went further in April 2020, formally discharging both the social media ban and pornography prohibition that had formed the basis of the original violations.
With her parole revocation overturned and the contested conditions removed, C.A.L. filed a civil rights lawsuit on June 1, 2020. Her complaint alleged that the Parole Board's actions violated her constitutional rights under both federal civil rights law and New Jersey state statutes.
The key legal question before the New Jersey Supreme Court was whether the timing requirements established in *Heck v. Humphrey* should apply to state civil rights claims. Under *Heck*, plaintiffs cannot file certain civil rights lawsuits while related criminal or administrative proceedings are ongoing if those lawsuits would necessarily challenge the validity of the underlying proceeding.
Justice Wainer Apter, writing for the unanimous court, extended the *Heck* framework to New Jersey state law. The court held that claims brought under the New Jersey Civil Rights Act and the New Jersey Tort Claims Act are subject to the same favorable-termination requirement as federal civil rights claims under Section 1983.
This ruling means that individuals in New Jersey who wish to challenge government actions related to criminal proceedings must wait until those proceedings conclude in their favor before filing certain types of civil rights lawsuits. The decision provides clarity for both plaintiffs and courts about when such claims can proceed.
The court also addressed whether C.A.L.'s claims were time-barred under applicable statutes of limitations. While the syllabus does not detail the court's complete analysis on this point, the timing question was central to the case given that C.A.L. filed her lawsuit after the favorable resolution of her parole revocation.
The decision has broader implications for civil rights litigation in New Jersey. Individuals who believe their constitutional rights were violated during criminal proceedings, parole hearings, or related administrative actions must now consider the *Heck* timing requirements when planning legal challenges.
For parolees specifically, the ruling affects how and when they can challenge conditions of supervision they believe are unconstitutional. While the decision in *K.G. v. State Parole Board* established that internet restrictions must be individually tailored, the *C.A.L.* decision clarifies the procedural requirements for bringing such challenges.
The unanimous nature of the decision suggests strong agreement among the justices about applying federal civil rights precedent to state law claims. This alignment between federal and state timing requirements may streamline civil rights litigation and reduce confusion about when claims can be filed.
Legal practitioners representing individuals in similar situations will need to carefully consider the timing of civil rights claims, ensuring that related criminal or administrative proceedings have concluded favorably before filing suit. The decision reinforces the importance of understanding both federal and state civil rights frameworks when advising clients about potential constitutional violations by government actors.