Kyles v. Garrett

First successful appeal of summary judgement of a 1983 civil suit alleging ex post facto in a Texas parole matter.


Kyles alleged a violation of ex post facto in the administration of his parole hearing. 42 U.S.C. 1983 was the vehicle in which this challenge was brought. No other case has successfully claimed this. Kyles sought solely prospective relief and thus did not imply the invalidity of his sentence which would violate Heck v. Humphrey.

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Reference Info:Appellate Brief | Federal, 5th Circuit, Texas | United States

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