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Oct. 21, 2025

9th Circuit rules says no-contest pleas can't be used to bar civil rights claims

In a first-of-its-kind ruling, the 9th Circuit held that federal evidence rules bar using a nolo contendere plea to defeat a §1983 claim under Heck v. Humphrey, reinstating a prisoner's excessive-force lawsuit against two Kern Valley State Prison officers.

The 9th U.S. Circuit Court of Appeals on Monday revived a California prisoner's excessive-force lawsuit, ruling that federal evidence rules prohibit using a nolo contendere plea to bar a civil claim under Heck v. Humphrey -- a question the court had never squarely addressed until now.

"Treatment of nolo pleas under Rule 410 reflects the long-standing recognition that the nolo plea constitutes a special creature under the law," Judge William A. Fletcher wrote. "I...

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