## Facts

- Virginia police officers searched John Franklin Prosise’s apartment and found materials associated with manufacturing phencyclidine (PCP).
- Prosise was charged in Virginia state court with manufacturing a controlled substance.
- Prosise pleaded guilty; during the plea hearing, an officer briefly described the search and discovery of the materials.
- Prosise did not file a motion to suppress and did not litigate the Fourth Amendment legality of the search in the criminal case.
- After conviction, Prosise filed a federal damages action under 42 U.S.C. § 1983 against the officers, alleging an unconstitutional search in violation of the Fourth Amendment.

## Issues

1. Whether, under 28 U.S.C. § 1738 and Virginia issue-preclusion rules, a state conviction based on a guilty plea bars a later federal § 1983 action challenging the constitutionality of the search.
2. Whether a guilty plea constitutes an implied admission that the search was lawful, or a waiver that bars a later § 1983 Fourth Amendment damages claim.

## Decision

- The Supreme Court unanimously affirmed the Fourth Circuit.
- The Court held that Virginia collateral estoppel principles did not bar the § 1983 suit because the search’s legality was not actually litigated, was not necessarily decided, and was not essential to the guilty-plea conviction.
- The Court rejected the argument that Prosise’s guilty plea, by itself, either admitted the legality of the search or waived a later § 1983 damages claim based on the search.

## Legal Principles

- Under 28 U.S.C. § 1738, federal courts must give state-court judgments the same preclusive effect they would receive under the rendering state’s law.
- Under Virginia issue-preclusion doctrine, an issue is precluded only if it was actually litigated and determined, and only if the determination was necessary to the prior judgment.
- A conviction based on a guilty plea conclusively resolves the defendant’s criminal culpability for the offense, not the legality of police conduct that was not litigated in the plea proceeding.
- A defendant’s decision to plead guilty, despite having an opportunity to raise a Fourth Amendment suppression issue, does not alone bar a later, distinct § 1983 damages claim challenging an allegedly unconstitutional search.

## Conclusion

The Court held that a state guilty-plea conviction does not preclude a later § 1983 Fourth Amendment damages action where the legality of the search was not actually litigated or necessary to the conviction, and the plea does not itself amount to an admission or waiver barring the civil claim.


Haring v. Prosise, 462 U.S. 306 (1983)