Ralph Smith, Jr. v. James Hood, III, 900 F.3d 180

Background

Ralph Arnold Smith was arrested after an alleged murder-for-hire plot; a Chancery Court found him psychotic and ordered involuntary inpatient civil commitment at the Mississippi State Hospital.
Smith sued under 42 U.S.C. § 1983 and Title II of the ADA against the Mississippi Department of Mental Health, State Hospital personnel, prosecutors, and private attorneys, seeking damages and alleging conspiracies to unlawfully commit him.
Defendants moved to dismiss under Rules 12(b)(1) and 12(b)(6), invoking Heck v. Humphrey, sovereign immunity, prosecutorial/witness immunity, and other defenses; the district court dismissed all federal claims and declined supplemental jurisdiction over state-law claims.
On appeal, Smith conceded Heck would bar claims that necessarily challenge the validity of his commitment but argued some claims were conceptually distinct from the commitment itself.
The Fifth Circuit affirmed dismissal of ADA claims against the State under Eleventh Amendment/Georgia analysis and affirmed dismissal of most § 1983 claims as barred by Heck or for failure to state a constitutional violation.
The Fifth Circuit vacated and remanded the district court's dismissal of one § 1983 due-process claim alleging unlawful use of leather and metal restraints by certain hospital defendants, viewing it as a conditions-of-confinement claim not barred by Heck.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Title II of the ADA abrogates state sovereign immunity for Smith's claims against DMH	ADA abrogates immunity; state violated Title II	State invoked Eleventh Amendment immunity; Georgia framework requires showing Title II conduct also violated Fourteenth Amendment or valid abrogation	Dismissal affirmed: Smith failed to apply Georgia framework or identify specific Title II violations
Whether Heck bars Smith's § 1983 claims arising from involuntary civil commitment	Heck should not bar claims that are temporally/conceptually distinct from commitment	Heck bars claims that would necessarily imply invalidity of commitment; should apply to civil commitment context	Most § 1983 claims dismissed: court treated Heck as applicable and found most claims would call commitment into question or lacked constitutional basis
Whether alleged failures (risk assessment, periodic evaluations, placement in forensic unit, unlicensed treatment) state § 1983 claims	These acts violated Smith's federal rights and are distinct from commitment validity	Defendants: either barred by Heck or insufficient to allege a federal constitutional violation	Dismissal affirmed: Smith failed to plead a coherent § 1983 legal theory showing denial of federal rights
Whether use of leather and metal restraints violated due process (conditions-of-confinement)	Restraints amounted to unconstitutional bodily restraint violating due process	Defendants argued such claims would necessarily challenge legitimacy/length of commitment and are barred	Vacated and remanded: Court held the restraints claim is conceptually distinct (conditions of confinement) and not barred by Heck; remanded for further proceedings

Key Cases Cited

Heck v. Humphrey, 512 U.S. 477 (bar on § 1983 claims that would imply invalidity of conviction/sentence)
United States v. Georgia, 546 U.S. 151 (framework for when Title II abrogates state sovereign immunity under the Fourteenth Amendment)
Youngberg v. Romeo, 457 U.S. 307 (liberty from bodily restraint is core due-process interest for involuntary commitment)
Wilkinson v. Dotson, 544 U.S. 74 (distinguishing challenges to confinement conditions from attacks on fact/length of confinement)
Huftile v. Vonseca, 410 F.3d 1136 (applying Heck to civil commitment context)
Ballard v. Burton, 444 F.3d 391 (analysis of whether § 1983 claims necessarily undermine convictions)
Bush v. Strain, 513 F.3d 492 (analytical, fact-intensive approach to Heck inquiry)
City of Chicago v. International College of Surgeons, 522 U.S. 156 (standards for exercising supplemental jurisdiction)