The following excerpt is from Hamilton v. Bosenko, No. 2:16-cv-0968 KJN P (E.D. Cal. 2016):
Heck does not, however, bar a plaintiff from bringing an action asserting these claims during the pendency of the criminal action. Wallace v. Kato, 549 U.S. 384, 393-94 (2007), explains that such action should instead be stayed:
459 U.S. at 393-94.
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