Labels:airplane | bulletin board | hakham | reckoner | sky OCR: year Rotter Cavanaugh, 984 F.2d 120 124 (4th Cir 1993). Simply put, release for Roller is "neither asked nOT ordered" under his $1983 action. Gerstein, 420 U.S at 107 n. The Fourth Circuit Court of Appeals correctly decided this issue and Roller's action is properly brought under 1983 Petitioner also argues that Roller should have first sought redress in the South Carolina State Courts before asking for federal relief. While exhaustion of state remedies may be necessary for habeas purposes the same is 1ou true of $1983 actions, Patsy Board of Regents 457 U.S. 496 (1982) -15. Roter Slate