Singleton v. Hamm Brief: Federal Courthouses Should Hear Over-Detention Claims
America is home to less than five percent of the world’s population, yet it incarcerates almost a quarter of all prisoners. The rate of incarceration in the United States has increased almost sixfold in the last half-century. As a result, prisons are understaffed and overcrowded. This problem is particularly acute in Alabama, which has the most overcrowded prison system in the country.
To mitigate excessive imprisonment, Alabama enacted its Mandatory Release Law in 2015. The law requires the Department of Corrections to release incarcerated Alabamians to the Board of Pardons and Paroles at specified times before their release date. The Board then converts the remainder of their sentences to parole.
The plaintiffs allege that the defendants imprisoned them beyond the time limits allowed by this law. Plaintiffs Derrick Singleton, Ray Traylor, and Deandra Whitehead allege that they were imprisoned unlawfully for 61 days, 2 days, and 124 days, respectively. They brought a federal civil rights lawsuit challenging their over-detention. The district court dismissed their suit, holding it barred by a Supreme Court decision called Heck v. Humphrey, which held that prisoners cannot challenge their convictions or sentences through a civil rights suit. The plaintiffs’ case is now on appeal to the Eleventh Circuit.
Cato filed a brief urging that court to reverse the decision below. The federal civil rights law, § 1983, was enacted to ensure accountability for rights violations. Heck bars only those § 1983 lawsuits and is inapplicable here, where the plaintiffs do not challenge their sentences and are no longer in custody but instead ask the courts to recognize the legal effect of the sentences they were given. The courthouse doors should be open to important claims like theirs.