CHARLES STOKES, Beneficiary v. JASON GARNETT, Trustee, Chief of Parole Division for Illinois DOC

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted June 16, 2026*
Decided July 20, 2026
Before
FRANK H. EASTERBROOK, Circuit Judge
JOHN Z. LEE, Circuit Judge
REBECCA TAIBLESON, Circuit Judge
No. 25-1373
CHARLES STOKES, Beneficiary,
Plaintiff-Appellant,
v.
JASON GARNETT, Trustee, Chief of
Parole Division for Illinois DOC,
Defendant-Appellee.
Appeal from the United States District
Court for the Northern District of
Illinois, Eastern Division.
No. 24 C 3716
Jorge L. Alonso,
Judge.
O R D E R
Charles Stokes, who is serving mandatory supervised release in Illinois,
challenges the dismissal of his complaint under 42 U.S.C. § 1983 asserting that he was
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 25-1373 Page 2
unlawfully confined beyond the end of his sentence. But a writ of habeas corpus—not
§ 1983—is the proper vehicle for such a challenge, so we affirm.
We accept as true the facts alleged in Stokes’s complaint and give him the benefit
of all reasonable inferences from those allegations. Courtney v. Butler, 66 F.4th 1043, 1046
(7th Cir. 2023). In 2010, Stokes pleaded guilty to predatory criminal sexual assault. He
says he was sentenced to eight years’ imprisonment, a term of which he would be
required to serve at least 85%, as well as three years’ mandatory supervised release. But
after serving his prison sentence, he claims, he could not find housing suitable for
supervised release, so he was held in prison for another six years. He was not released
until January 13, 2021, and he states that he is now serving an indefinite term of
supervised release.
In 2024, he brought this civil-rights suit against Jason Garnett, the Chief of Parole
for the Illinois Department of Corrections. See 42 U.S.C. § 1983. Stokes alleged that
Garnett unlawfully incarcerated him for six years beyond his original release date and
unconstitutionally enforced conditions of supervised release for an indefinite period,
even though his sentence supposedly only imposed three years of supervised release.
Stokes sought damages and an order preventing Garnett from continuing to enforce the
supervised-release conditions.
The district court granted Garnett’s motion to dismiss the complaint for failure to
state a claim. The court pointed out, first, that there is no respondeat superior liability
under § 1983, and Stokes failed to allege that Garnett personally caused the alleged
constitutional deprivation. The court also determined that Stokes’s claims were barred
under Heck v. Humphrey, 512 U.S. 477, 486–87 (1994), because his sentence had not first
been declared invalid.
We do not need to reach the Heck issue because Stokes should have filed a
petition for a writ of habeas corpus, not a claim under § 1983. The thrust of Stokes’s
complaint is that despite being sentenced to a finite, three-year term of mandatory
supervised release, he is now serving a term that is indefinite. If Stokes’s allegations are
true, he has likely already served his term of mandatory supervised release. In effect,
then, Stokes is seeking to enforce his sentence and hold the State to only a three-year
term of mandatory supervised release.
The Supreme Court has held time and again that when the relief a state prisoner
“seeks is a determination that he is entitled to immediate release or a speedier release
from that imprisonment, his sole federal remedy is a writ of habeas corpus.” Preiser v.

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No. 25-1373 Page 3
Rodriguez, 411 U.S. 475, 500 (1973); see also Wilkinson v. Dotson, 544 U.S. 74, 81 (2005)
(“[T]he Court has focused on the need to ensure that state prisoners use only habeas
corpus (or similar state) remedies when they seek to invalidate the duration of their
confinement—either directly through an injunction compelling speedier release or
indirectly through a judicial determination that necessarily implies the unlawfulness of
the State’s custody.” (emphasis in original)). “Challenges ‘close to the core of
habeas corpus’ must be brought, if at all, under ‘the specific federal habeas corpus
statute’—[such as] § 2254—which was ‘explicitly and historically designed to provide
the means for a state prisoner to attack the validity of his confinement.’” Fernandez v.
United States, 608 U.S. --, 146 S. Ct. 1292, 1301 (2026) (quoting Preiser, 411 U.S. at 489).
This is true for challenges, like Stokes’s, to a term of supervised release, which “is
considered part of a defendant’s sentence.” Pettis v. United States, 129 F.4th 1057, 1061
(7th Cir. 2025); see also United States v. Kappes, 782 F.3d 828, 837 (7th Cir. 2015). Stokes
may not short-circuit this process and “use a § 1983 action to challenge the fact or
duration of his confinement.” Wilkinson, 544 U.S. at 78 (citation modified). If Stokes
wishes to challenge the imposition of these conditions, he must do so in a habeas
proceeding. See Tobey v. Chibucos, 890 F.3d 634, 651 (7th Cir. 2018); Williams v. Wisconsin,
336 F.3d 576, 579–80 (7th Cir. 2003).
AFFIRMED

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