Reza Ahmadi v. Lorie Davis, Director, 705 F. App'x 306

Ahmadi, a former Texas prisoner, filed a 42 U.S.C. § 1983 suit challenging actions by the Texas Board of Pardons & Paroles and its Director, seeking relief for alleged unlawful confinement July 2, 2012–May 16, 2014.
The district court dismissed his § 1983 complaint on Eleventh Amendment immunity, Heck v. Humphrey grounds, and for failure to state a claim.
Ahmadi argued (1) prospective injunctive relief is not barred by the Eleventh Amendment, (2) his sentence was invalidated because a prior § 2254 habeas petition was dismissed as moot, and (3) he sufficiently pleaded a § 1983 claim.
The panel reviewed Eleventh Amendment immunity de novo and considered whether the Ex Parte Young exception for prospective injunctive relief applied.
The court noted Ahmadi had been released to mandatory supervision and did not specify particular prospective relief; he primarily sought monetary relief for past confinement.
Because his conviction/sentence had not been invalidated on the merits, Heck barred damages claims that would imply the unlawfulness of his confinement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Eleventh Amendment bars suit against state officials	Ahmadi: prospective injunctive relief escapes Eleventh Amendment	State: suit seeks money from state actors; Eleventh Amendment bars it	Held: barred; Ahmadi sought monetary relief and did not adequately plead prospective, individual-capacity injunctive relief
Whether Ex Parte Young permits relief despite Eleventh Amendment	Ahmadi: seeks prospective relief under Ex Parte Young	State: no particularized prospective relief alleged; Ahmadi is released, so relief unclear	Held: Ex Parte Young inapplicable because relief not particularized and release undermines prospective remedy
Whether Heck prevents § 1983 damages for alleged unconstitutional confinement	Ahmadi: prior § 2254 dismissal as moot effectively invalidated sentence	State: conviction/sentence not overturned on merits; Heck bars damages that imply invalidity	Held: Heck bars damages; Ahmadi did not show conviction/sentence was invalidated on the merits
Whether dismissal for failure to state a claim was erroneous	Ahmadi: he pleaded all elements of § 1983 claim	State: claims barred by immunity and Heck; court need not reach merits	Held: Court affirmed dismissal on Eleventh Amendment and Heck grounds and did not reach merits of the § 1983 pleading

Heck v. Humphrey, 512 U.S. 477 (1994) (damages claims challenging conviction or sentence barred unless conviction reversed)
Ex Parte Young, 209 U.S. 123 (1908) (narrow exception to Eleventh Amendment for prospective injunctive relief)
McKinley v. Abbott, 643 F.3d 403 (5th Cir. 2011) (discussing Ex Parte Young and Eleventh Amendment limits)
Hale v. King, 642 F.3d 492 (5th Cir. 2011) (standard for reviewing Eleventh Amendment immunity)
K.P. v. LeBlanc, 627 F.3d 115 (5th Cir. 2010) (Eleventh Amendment bars monetary suits against state)
Edwards v. Balisok, 520 U.S. 641 (1997) (Heck principles extend to certain prison disciplinary claims)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (distinguishing types of habeas relief and § 1983 remedies)
Weinstein v. Bradford, 423 U.S. 147 (1975) (release from custody may moot prospective relief)
McGrew v. Texas Bd. of Pardons & Paroles, 47 F.3d 158 (5th Cir. 1995) (parole challenges implicate Heck)