Curry v. MDOC, 3:13-cv-00076

Curry, a pro se prisoner, filed §1983 and §2254 actions challenging confinement conditions, two cocaine convictions, and sentence calculations in the Southern District of Mississippi.
Plaintiff sues MDOC, Lee County Circuit Court, Monroe County Circuit Court, and Oxford County Jail seeking damages, transfer, or release.
Claims include past and imminent danger conditions (e.g., hygiene, medical care, recreation) and alleged improper credit for time served and detainers.
Court permitted in forma pauperis status but sua sponte considered dismissal under 28 U.S.C. §1915(e)(2).
Court determines MDOC is an arm of the State; state-official capacity injunctive claims proceed, but MDOC claims are barred and state-law claims are dismissed.
Judicial immunity and Heck v. Humphrey bar analysis lead to dismissal of the state-court and conviction-based §1983 claims; habeas claims unexhausted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are §1983 claims against MDOC barred by Eleventh Amendment immunity?	Curry sues MDOC for unconstitutional conditions and wrongful convictions.	MDOC is an arm of the State and not a proper §1983 defendant; state immunity applies.	MDOC claims dismissed; MDOC not a §1983 person; official-capacity injunctive claims allowed.
Do state courts/law judges enjoy judicial immunity to §1983 challenges?	Judge Pounds erred in trial-related actions affecting Curry’s convictions.	Judicial actions within official capacity are immune from §1983 suit.	State courts and Judge Pounds are absolutely immune; claims dismissed.
Does Heck v. Humphrey bar §1983 challenges to state convictions and sentences?	Convictions/sentences violated rights; seek relief in §1983 action.	Success would undermine the validity of confinement; must be via state/court relief.	Heck bar applies; §1983 claims dismissed as to convictions/sentences with prejudice; non-barred aspects proceed.
Are the habeas claims exhausted and properly asserted in §2254 proceedings?	Requests accelerated release based on alleged illegality.	State remedies must be exhausted before federal habeas; only partial exhaustion shown.	Habeas claims unexhausted and dismissed without prejudice; remainder of case proceeds.

Denton v. Hernandez, 504 U.S. 25 (1992) (frivolous or malicious dismissal authority under §1915)
Ali v. Higgs, 892 F.2d 438 (5th Cir. 1990) (courts may sua sponte address affirmative defenses)
Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (state not a ‘person’ under §1983; Eleventh Amendment implications)
Hulsey v. Owens, 63 F.3d 354 (5th Cir. 1995) (absolute judicial immunity for official acts)
Ballard v. Wall, 413 F.3d 510 (5th Cir. 2005) (four-factor test for judicial immunity scope)
Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity threshold and scope)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (§1983 claims challenging state confinement duration—Heck framework)
Heck v. Humphrey, 512 U.S. 477 (1994) (§1983 relief barred where success would imply invalidation of confinement)
O’Sullivan v. Boerckel, 526 U.S. 838 (1999) (exhaustion requirement for habeas petitions)
Johnson v. McElveen, 101 F.3d 423 (5th Cir. 1996) (dismissal of §1983 claims when state convictions not yet invalidated)
Hamilton v. Lyons, 74 F.3d 99 (5th Cir. 1996) (imposition of strike under 28 U.S.C. § 1915(g))