Sexually Violent Persons Commitment Act

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7^th Circuit Court of Appeals

Case Name: Timothy Bell v. Kwame Raoul

Case No.: 23-1757

Officials: Hamilton, Scudder, and Lee, Circuit Judges.

Focus: Sexually Violent Persons Commitment Act

Bell, who, having completed a sentence for sexual assault, remained incarcerated in an Illinois prison for over 16 years under the state’s Sexually Violent Persons Commitment Act. Bell sued two state officials under 42 U.S.C. § 1983, asserting that his civil commitment had exceeded the Act’s allowed duration. The district court dismissed Bell’s case, invoking the Supreme Court’s 1994 decision in Heck v. Humphrey as a bar to his claims.

The central ruling in the case is that Heck v. Humphrey’s favorable-termination requirement, preventing prisoners from using § 1983 to challenge the fact or duration of their confinement unless their conviction or disciplinary sanction has been invalidated, is applicable to civil detainees, including those confined under the Illinois Sexually Violent Persons Commitment Act. The court argued that, akin to a prisoner contesting a criminal conviction or sentence, a civil detainee cannot bring a § 1983 lawsuit against a state official for violating constitutional rights if a judgment in the plaintiff’s favor would imply the invalidity of the confinement, unless the grounds for the confinement have already been set aside in other proceedings. This conclusion applies irrespective of whether the individual is civilly committed or criminally imprisoned.

Moreover, the court emphasized that Bell’s transition from confinement to home confinement did not alter its conclusion. The Heck bar remains in effect until the judgment causing the detention is invalidated, even after a detainee’s release. Consequently, Bell must await a favorable termination of his civil commitment before pursuing relief under § 1983 for his alleged excessively prolonged confinement.

Affirmed.

Decided 12/20/23

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