Igo v. Governor of Commonwealth of Massachusetts, 4:15-cv-40088

Petitioner John Igo, proceeding pro se, filed a habeas petition challenging his civil commitment under Mass. Gen. Laws ch. 123, § 16 after a Cambridge District Court finding of incompetence to stand trial (June 29, 2015).
Igo alleged procedural defects in the commitment proceedings (e.g., prior denial, subsequent refiled petition, signature signed in lobby) and asserted related problems with multiple criminal dockets (Cambridge, Woburn, Boston Municipal Court).
He sought federal review of the commitment and related state criminal case actions and alleged misrepresentation by court-appointed MHLU counsel.
Igo filed two motions to proceed in forma pauperis (granted) and a motion to correct the case title (denied).
The court construed the commitment challenge as a § 2254 habeas claim but found Igo had not alleged that he exhausted available state remedies nor any exception to exhaustion.
Court dismissed the habeas petition for failure to exhaust state remedies and closed the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Igo's civil commitment pursuant to G.L. c.123 §16 can be reviewed via federal habeas	Igo argued commitment was improper and procedurally defective; sought federal review and relief	Commonwealth (respondents) implicitly argued state remedies and processes are available and exhaustion required	Court treated claim as cognizable under §2254 but dismissed for failure to exhaust state remedies
Whether Igo exhausted state remedies before filing federal habeas	Igo did not allege exhaustion or identify attempts to pursue state remedies	Respondents relied on statutory/state procedures available (e.g., G.L. c.123 §9(b)) and exhaustion requirement	Court held petitioner bears burden to show exhaustion; he did not, so petition dismissed
Whether exceptions to exhaustion apply (e.g., cause and prejudice, or extraordinary circumstances)	Igo did not assert or allege facts supporting an exhaustion exception	Respondents contended no exceptional circumstances shown	Court found no allegations of an exhaustion exception and declined to excuse failure to exhaust
Proper procedural handling of in forma pauperis and case title motion	Igo sought waiver of filing fee and title correction	Respondents did not contest pauper status; title correction unnecessary	Court granted in forma pauperis and denied motion to fix title

Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus is vehicle to challenge legality of custody and seek release)
Vitek v. Jones, 445 U.S. 480 (1980) (due process protections apply to involuntary transfer/commitment of prisoners on mental-health grounds)
Rose v. Lundy, 455 U.S. 509 (1982) (federal habeas petitioners must exhaust state remedies before federal review)
Ahmed v. Rosenblatt, 118 F.3d 886 (1st Cir. 1997) (pro se pleadings are construed liberally)
Adelson v. DiPaola, 131 F.3d 259 (1st Cir. 1997) (exhaustion requires fair presentation of federal claims to state courts)
Picard v. Connor, 404 U.S. 270 (1971) (state remedies are exhausted only when federal claims were fairly presented to state courts)
Barresi v. Maloney, 296 F.3d 48 (1st Cir. 2002) (petitioner bears heavy burden to prove exhaustion)