Michael Huftile v. L C Miccio-Fonseca

In this case, we must decide a question of first impression: Does the favorable termination rule of Heck v. Humphrey, 512 U.S. 477 , 114 S.Ct. 2364 , 129 L.Ed.2d 383 (1994), apply to civil commitments under California’s Sexually Violent Predators Act? We conclude that the Heck rule applies. We therefore affirm the district court’s dismissal of Huftile’s § 1983 action for damages and declaratory relief. However, we reverse the dismissal of his claim for prospective injunctive relief under Heck , and remand for further proceedings concerning this form of relief.

I. Background

Michael Huftile filed a 42 U.S.C. § 1983 complaint seeking damages, declaratory relief, and injunctive relief against Dr. L.C. Miccio-Fonseca in federal district court on July 17, 2003. When he filed the complaint, Huftile was being detained under California’s Sexually Violent Predators Act (“SVPA”). The SVPA provides for a two-year term of civil commitment if a court or jury determines beyond a reasonable doubt that an individual is a “sexually violent predator.” Cal. Welf. & Inst.Code § 6604. Huftile contends that Dr. Miccio-Fonseca’s “policies, practices, and customs” in performing an SVPA evaluation of…