When a dispute broke out between her adult children at her home in Springfield, Massachusetts, in November 2018, Guistina Aprileo called the police hoping to defuse the situation. Instead, the encounter spiraled after she argued with one of the responding officers.

By the end of it, Aprileo was on the ground, handcuffed, with a fractured elbow. She was later charged with disorderly conduct, resisting arrest and assault and battery on a police officer. Instead of taking a plea or going to trial, she agreed to three months of pretrial probation in exchange for having the charges against her dropped. After she completed probation, the charges were dismissed without any guilty plea, admission or conviction.

Months later, Aprileo filed a lawsuit in state court against the City of Springfield and the three officers who responded to her 911 call. The heart of her case was an excessive force claim against Officer Richard T. Ward, the one who allegedly used excessive force, and two claims against Officers Thalia Castro and Jason Bacis for failing to stop him.

The defendants argued that the case was barred by the U.S. Supreme Court's decision in Heck v. Humphrey, which prevents civil rights suits that would effectively call into question a valid criminal conviction.

When the suit was removed to federal court, the officers said that Aprileo's pretrial probation should effectively be treated like a conviction for purposes of the Heck doctrine, arguing for a more functional, rather than literal, interpretation of the word "conviction."

In doing so, the defendants pressed their argument on an area of federal law where the First Circuit had not yet clearly ruled — but where most other circuits had already held that the Heck bar doesn't apply when there isn't a literal conviction.

A Massachusetts federal court rejected the officers' argument. Then, on Nov. 10, 2025, the First Circuit weighed in with a decision in favor of Aprileo.

"Because Aprileo was not convicted of any crime, and she secured a dismissal of the charges against her without a guilty plea or any admission of wrongdoing, the Heck bar does not apply," U.S. Circuit Judge Julie G. Rikelman wrote in an opinion on behalf of a three-judge panel.

The ruling harmonized the First Circuit with sister courts around the country that have determined the Heck doctrine is inapplicable in the absence of an underlying conviction. Five U.S. Courts of Appeals — the Sixth, Eighth, Ninth, Tenth and Eleventh circuits — already held that, specifically, the dismissal of criminal charges after a defendant's successful completion of pretrial probation does not trigger the Heck bar.

Emma Freeman, a founder and partner at Pace Freeman LLP who argued on behalf of Aprileo before the First Circuit, told Law360 that "the court got it exactly right."

"A conviction under Heck has to be an actual conviction, not something that looks like a conviction or smells like a conviction, but a real conviction," Freeman said.

Freeman involved her students at the University of Minnesota Law School, where she co-directs the Civil Rights Appellate Clinic, in the work on the appeal. She said it was a "treat" for the students to litigate a matter of first impression in the First Circuit.

"We had the privilege of being able to collaborate with some of the attorneys who had litigated these cases in other areas of the country," she said.

The case was remanded to the district court and is now before U.S. District Judge Mark G. Mastroianni.

Brandon L. Garrett, a legal scholar at Duke University School of Law, called the Aprileo ruling "quite straightforward," as it clarifies an aspect of the Heck doctrine that was already settled in other federal circuits.

"Heck only applies to a conviction. I think that this has always been clear — that the Heck rule is only about bringing a civil lawsuit challenging a conviction when the conviction is still on the books," he said.

The Ruling's Impact

Though still recent, the decision in Aprileo has already begun to appear in subsequent civil rights cases. In December, a federal judge in Massachusetts cited the case in ruling that a civil rights lawsuit filed by a couple of homeowners against the Town of Hanson, Massachusetts, and officers of its police department could proceed.

In that case, Charles Williams, who is Black, was arrested in January 2022 after he called the police for assistance when a group of white males allegedly cornered him and threatened him in front of his home. Williams, who said in a complaint filed in May 2024 that he brandished a work knife because he feared for his safety, was charged with felony assault with a dangerous weapon.

The charges were later dismissed, and Williams sued the town with a slew of civil rights claims, including lack of probable cause, malicious prosecution, selective enforcement, and due process violation, saying the officers chose to believe the white men, who painted Williams as the aggressor, over his own account.

When the defendants moved to end the case on July 29, 2025, they argued that Williams' malicious prosecution claim was barred under Heck because he accepted a pretrial disposition on his charges and "failed to obtain a favorable decision" in the underlying criminal case giving rise to his claim.

U.S. District Judge Brian E. Murphy, however, allowed the malicious claim to move forward in a Dec. 1 order, citing the Aprileo ruling that had come down less than three weeks prior. The case is still pending.

The Aprileo decision was cited more recently in another lawsuit brought by another Massachusetts resident, Gerard Paul Brophy, who was charged with battery of a police officer after an arrest in the parking lot of a 7-Eleven store. The charges were later dismissed after a period of pretrial probation, and Brophy sued for false arrest, false imprisonment, malicious prosecution, and abuse of process in federal court.

The officer asked the court to dismiss the suit, saying the Heck doctrine "unquestionably" barred Brophy's claims. But on Feb. 19, U.S. District Judge Allison D. Burroughs disagreed, allowing the claims to go ahead in an order where she cited the ruling in Aprileo.

Heck's Three-Part Framework

The Heck doctrine generally prevents people from bringing civil rights lawsuits under Section 1983 of Title 42 of the U.S. Code — which codifies federal civil rights provisions Congress adopted at the end of the Civil War — if their claims would undermine an existing criminal conviction.

Because criminal cases can end in many different ways, and because state procedures vary, the doctrine often requires courts to delve into the specific circumstances of a case, experts say.

Overall, courts typically analyze Heck through a three-part framework: There must first be a criminal conviction. Second, that conviction must still be valid, meaning it has not been vacated by a court. Third, a civil rights claim must necessarily imply that the conviction was invalid. If those conditions are met, the civil case is barred.

The Aprileo case centered on the first step of the Heck analysis: whether the plaintiff had a conviction at all. Specifically, it turned on whether Heck applies when a criminal case ends through pretrial probation rather than a conviction.

In the order, the First Circuit panel said the record in Aprileo's case was "crystal clear" that her pretrial probation agreement did not contemplate a conviction, require her to enter a guilty plea or otherwise admit to any facts or the sufficiency of any evidence against her. The panel also noted that the state court did not require any admissions of guilt from Aprileo as a condition of dismissing the charges against her.

"The Heck rule applies to claims that have the potential to 'render a conviction or sentence invalid'," the panel wrote. "But Aprileo was not convicted, and she was not sentenced. She did not plead guilty, and she did not stand trial. Nor did she admit to any facts about the events at her home in November 2018."

The panel emphasized that its holding was limited to the specific facts of Aprileo's case — including the nature of her pretrial probation agreement — and should not be read to mean that the Heck bar could never apply to plaintiffs who entered similar agreements. The court noted that Massachusetts law also permits probation following a finding or verdict of guilt, suggesting that in such circumstances, the doctrine could apply.

Karen Blum, a professor of civil procedure at Suffolk University Law School and expert in police misconduct litigation, told Law360 in an email that the Aprileo ruling expresses the "right view" of the Heck doctrine, and that she expects that other circuit courts that diverge on the issue — the Third and Fifth circuits — will soon adopt the same view, particularly in light of recent Supreme Court case law that further clarifies Heck.

Ruling in 2022 in Thompson v. Clark, the Supreme Court resolved a circuit split by ruling that a malicious prosecution lawsuit under Section 1983 did not require the plaintiff to show that an underlying criminal case ended with an affirmative indication of innocence to move forward.

And earlier on Friday, the court unanimously ruled in Oliver v. City of Brandon that a Mississippi street preacher convicted of violating a local antiprotest ordinance can use Section 1983 to challenge the ordinance as a violation of his First Amendment rights.

Marie Miller of the Institute for Justice, a nonprofit that submitted an amicus brief in support of Aprileo and in other Heck-related appeals, told Law360 that "time will tell" whether the Supreme Court would have to step in to resolve the enduring circuit split on the threshold issue of Heck, the one concerning what can be deemed a conviction.

Miller said it is "quite clear" that a judgment of conviction is needed to trigger the Heck bar, but acknowledged that courts do not apply uniformly what she said was a "bright line clear rule."

"There's lots of permutations of how a criminal case could go away short of conviction, so maybe the courts would need to wrestle with specific facts of criminal cases being disposed of without a conviction," she said. "Our position is that Heck wouldn't be triggered for anything without a judgment of a conviction."

Miller said the Heck doctrine conflicts with the text of Section 1983 itself, but added that the Institute of Justice has not taken a position on whether the doctrine should ultimately be struck down. She said courts should not be looking to extend it.

"The Heck bar itself kind of presumes that criminal cases take priority over civil enforcement of constitutional rights. And I'm not sure that that kind of basic presumption is right," Miller said. "You shouldn't be prevented from enforcing constitutional rights just because there's a state prosecution that happened."

--Editing by Haylee Pearl.

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