NEW ORLEANS (LN) — The Fifth Circuit on Monday remanded a civil rights lawsuit to the Southern District of Mississippi, clearing the way for the plaintiff to proceed with claims for prospective relief after the Supreme Court ruled that the Heck bar does not apply to such claims.
The Supreme Court reversed the Fifth Circuit’s judgment in Olivier v. City of Brandon, Mississippi, holding that the doctrine established in Heck v. Humphrey, 512 U.S. 477 (1994), does not bar Gabriel Olivier’s suit.
Olivier’s case involves allegations stemming from a prior conviction for violating a city ordinance. The Supreme Court held that because Olivier is seeking purely prospective relief, the Heck bar—which generally prevents civil rights plaintiffs from suing if a judgment in their favor would imply the invalidity of a prior criminal conviction—does not apply.
"This case is before us on remand from the Supreme Court," the Fifth Circuit wrote in a per curiam opinion.
The appellate court noted that the Supreme Court's decision specifically addressed the scope of the Heck bar of prospective relief.
"Accordingly, we REMAND this case to the district court for further proceedings consistent with the Supreme Court’s opinion," the Fifth Circuit stated.
The case was originally filed in the U.S. District Court for the Southern District of Mississippi. The Fifth Circuit had previously entered a judgment that the Supreme Court reversed.
The opinion was issued by a panel of Judges Wiener, Graves, and Douglas.
The mandate was certified as a true copy and issued on May 18, 2026.