Singleton et al v. Hamm et al.

Under Alabama law, most people who are imprisoned by the Alabama Department of Corrections are eligible for mandatory release between 3-12 months before the end of their sentence. The Department has an obligation to calculate these earlier release dates and ensure that people are released to parole supervision. However, hundreds, if not thousands of people every year are imprisoned past their latest release date, and they are confined in some of the most dangerous prisons in the country. The MacArthur Justice Center partnered with local attorneys to investigate and document this problem, using publicly available data from ADOC and accounts from dozens of people who were overdetained with no explanation. Among those were Derrick Singleton, Deandra Whitehead, and Ray Traylor. All three were eligible to go home to their families and their communities under the Mandatory Release Law and were held for a combined 187 days (about 6 months), beyond their release dates.

On August 8, 2024, in partnership with co-counsel from McGuire & Associates, Covington & Burling, and Kelly Guzzo, we filed a class action lawsuit in the Northern District of Alabama seeking justice for the thousands of people Alabama has illegally imprisoned. But without giving Mr. Singleton, Ms. Whitehead, and Mr. Traylor a chance to establish the merits of their claims, the district court dismissed the case on September 22, 2025, based on its misapplication of the proper Article III standing analysis and the Supreme Court’s decision in Heck v. Humphrey, 512 U.S. 477 (1994), which held that a challenge to a conviction or sentence must be made through habeas corpus rather than a civil rights suit.

On December 16, 2025, the MacArthur Justice Center and co-counsel filed an appeal in the U.S. Court of Appeals for the Eleventh Circuit. We’re arguing that the district court was wrong to dismiss the class’s claims under Heck v. Humphrey because Mr. Singleton, Ms. Whitehead, and Mr. Traylor do not challenge their convictions or sentences, are no longer imprisoned, and do not seek release from prison. Instead, they are seeking relief for being unlawfully held beyond their mandatory release dates. We’re also arguing that the district court incorrectly concluded that Mr. Singleton, Ms. Whitehead, and Mr. Traylor could not trace their over-detention to defendants in the Alabama Bureau of Pardons & Paroles, because those defendants play various important roles in the process that resulted in over-detention.