Cohen v. Longshore, 621 F.3d 1311 (10th Cir. Oct. 19, 2010) (immigration detainee brought civil rights action which was improperly dismissed: petitioner who has no available habeas remedy, through no lack of diligence on his part, is not barred by Heck from pursuing 1983 claim for unlawful confinement).
jurisdiction:
Tenth Circuit