Colvin v. LeBlanc, No. 19-30888 (5th Cir. 2021)Annotate this Case
Plaintiff appealed the dismissal of his 42 U.S.C. 1983 claims based on allegations that defendants illegally extradited him from Pennsylvania to Louisiana and impermissibly extended his state sentence by thirty years. Plaintiff's claims arose from a records clerk's reversion of his release date to the 2052 date, rather than the 2023 date, on the grounds that he had stopped serving his state sentence when he escaped from prison and that his state and federal sentences were intended to run consecutively.
The Fifth Circuit affirmed the district court's dismissal of plaintiff's sentence-based claims, but reversed and remanded with respect to the extradition-based claims. The court held that Heck v. Humphrey, 512 U.S. 477 (1994), does not present a jurisdictional hurdle that would require a remand of this case to state court. The court explained that Heck implicates a plaintiff's ability to state a claim, not whether the court has jurisdiction over that claim. As to plaintiff's claim regarding his sentence enhancement, the court concluded that a claim for speedier release is actionable by writ of habeas corpus, and a section 1983 damages action predicated on the sentence calculation issue is barred by Heck because success on that claim would necessarily invalidate the duration of his incarceration. The court also concluded that the district court never analyzed whether plaintiff's extradition-based claims were barred by Heck, and the district court should have considered whether his extradition-based claims survived Heck in the first instance. Furthermore, the district court should consider the qualified immunity, absolute immunity, and limitations ruling issues on remand. The court vacated in part and remanded for further proceedings.