In C.A.L. v. State (A-29-24/089655) (Decided January 27, 2026), the New Jersey Supreme Court held that the favorable-termination rule set forth in Heck v. Humphrey, 512 U.S. 477 (1994) applies to civil rights claims brought under the New Jersey Civil Rights Act (CRA), or the CRA and the New Jersey Tort Claims Act (TCA) jointly, just as it does to claims brought under 42 U.S.C. § 1983.
Under Heck, when a plaintiff’s civil rights claim necessarily impugns the validity of a criminal proceeding, the claim does not accrue until the criminal proceeding has been terminated in the plaintiff’s favor.
Facts of C.A.L. v. State
In 2005, C.A.L. was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL). The New Jersey State Parole Board imposed two special conditions on her parole: a ban on accessing social media and a ban on viewing or possessing pornography.
In February 2018, C.A.L. was arrested on a parole warrant for alleged violations of both conditions. C.A.L. challenged both conditions as unconstitutional. The Parole Board found clear and convincing evidence that C.A.L. violated both conditions, revoked C.A.L.’s PSL, and ordered her to remain incarcerated for twelve months.
C.A.L. appealed to the Appellate Division. While that appeal was pending, the Appellate Division decided K.G. v. State Parole Board, 458 N.J. Super. 1 (App. Div. 2019), which held that all conditions restricting Internet access should be reasonably tailored to the individual offender.
On February 6, 2020, the Parole Board vacated the 2018 revocation of C.A.L.’s PSL. It discharged the two conditions in April 2020. On June 1, 2020, the Parole Board issued a decision “find[ing] that clear and convincing evidence does not exist that [C.A.L.] violated” the conditions and that it “did not sustain any violation(s).”
On May 27, 2022, C.A.L. and her husband brought suit under the CRA and the TCA against the State, the Parole Board, and others. Counts One, Two, and Three of their complaint alleged a violation of C.A.L.’s substantive due process rights, gross negligence and failure to train, and deliberate indifference and failure to train. Count Four alleged false arrest/imprisonment.
Defendants successfully moved to dismiss all claims as time barred. The trial court held that (1) the false arrest/imprisonment claim accrued in February 2019, when C.A.L. was released from imprisonment; (2) the failure to train and failure to supervise claims accrued in February 2018, when C.A.L. was arrested; and (3) the substantive due process claim accrued in January 2019, when K.G. was decided.
The trial court found that even if Heck’s favorable-termination rule applied, a favorable termination occurred on February 6, 2020, when the Board vacated C.A.L.’s PSL revocation. The Appellate Division affirmed but held that the false arrest/false imprisonment claim accrued on the date of C.A.L.’s arrest.
NJ Supreme Court’s Decision in C.A.L. v. State
The New Jersey Supreme Court affirmed in part and reversed in part. The justices unanimously held that the Heck favorable-termination rule applies to civil rights claims brought under the CRA, or the CRA and TCA jointly, just as it does to claims brought under 42 U.S.C. § 1983.
The Court further found Counts One, Two, and Three of plaintiffs’ complaint were timely filed because the claims accrued, and the statute of limitations began to run, on June 1, 2020. However, any claim for false arrest/imprisonment would have accrued before May 27, 2020, and Count Four was therefore correctly dismissed as untimely.
Writing on behalf of the unanimous Court, Justice Wainer-Apter first addressed the Heck favorable-termination rule. In finding that it applies to claims brought under the CRA and the TCA in the same way it applies to claims brought under Section 1983 Justice Wainer-Apter noted that Heck’s favorable-termination requirement serves several salutary purposes: (1) it avoids parallel litigation in civil and criminal proceedings; (2) it precludes the inconsistent civil and criminal judgments that would occur if a plaintiff were to succeed in the tort action after having been convicted in the criminal case; and (3) it prevents civil suits from being improperly used as collateral attacks on criminal proceedings.
If a plaintiff challenges a criminal proceeding brought pursuant to legal process in a civil suit for damages under the CRA or TCA, no cause of action will accrue, and the claim cannot be brought, until the criminal proceeding has been terminated in the plaintiff’s favor. If, however, a plaintiff brings a cause of action that does not attack a criminal proceeding undertaken pursuant to legal process, no favorable-termination rule applies.
The New Jersey Supreme Court went on to find that after applying Heck, Counts One, Two, and Three of plaintiffs’ complaint were timely filed because the claims accrued, and the statute of limitations began to run, on June 1, 2020. As Justice Wainer-Apter explained, “Because Counts One, Two, and Three allege the wrongful initiation of legal process and necessarily impugn the validity of the parole revocation proceedings against C.A.L., Heck’s favorable-termination rule applies.”
The New Jersey Supreme Court rejected the Parole Board’s contention that plaintiffs’ claims are still time-barred because the February 6, 2020 decision or the discharge of the two special conditions in April 2020 constitute a favorable termination of C.A.L.’s parole proceedings. According to the Court, the finding that C.A.L. had violated special conditions of her parole was not vacated until June 1, 2020, and only the June 1, 2020 decision allowed C.A.L. to collaterally attack the constitutionality of the conditions in a civil case.
Finally, the New Jersey Supreme Court affirmed the dismissal of Count 4. “It is not clear whether such a warrant would constitute ‘legal process,’ and C.A.L. may therefore have been arrested and detained for some period without legal process,” Justice Wainer-Apter wrote. “Nonetheless, the statute of limitations on a claim for false arrest/false imprisonment begins to run when ‘legal process’ commences, and despite the lack of information in the record, legal process for C.A.L. clearly commenced long before May 27, 2020, two years before plaintiffs filed the complaint.”
Therefore, the Court found that even if C.A.L. could state a claim for false arrest/imprisonment because she was arrested and detained for some period without legal process, that claim was correctly dismissed as untimely.
