Can a state prisoner challenge the constitutionality of state parole procedures in a civil rights action?

State prisoners may challenge the constitutionality of state parole procedures in an action under Section 1983 seeking declaratory and injunctive relief. Wilkinson v. Dotson, 544 U.S. 74, 76 (2005). Section 1983 remains available for procedural challenges where success in the action would not necessarily spell immediate or speedier release for the prisoner. Id. at 81 ("[H]abeas remedies do not displace 1983 actions where success in the civil rights suit would not necessarily vitiate the legality of (not previously invalidated)

Page 4

state confinement.")