Case Explained: Non-Argument Calendar MICHAEL TOWNES v. UNITED STATES OF AMERICA UNITED STATES DEPARTMENT OF JUSTICE (DOJ) FEDERAL BUREAU OF INVESTIGATION (FBI) DEPARTMENT OF HOMELAND SECURITY (DHS) TRANSPORTATION SECURITY ADMINISTRATION (TSA), et al

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-05 Docket: 1:25-cv-06792-ELR The Eleventh Circuit affirmed the district court’s dismissal of Michael Townes’s complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B). The court held that Townes failed to establish Article III standing because he did not allege a specific, imminent threat of future harm required for declaratory and injunctive relief, noting that past exposure to illegal conduct does not constitute present injury without continuing adverse effects. Additionally, the court ruled that Townes’s claims were premature under *Heck v. Humphrey*, as a judgment in his favor seeking a declaration that his conviction was unconstitutional would necessarily imply the invalidity of that conviction, which had not yet been reversed, expunged, or invalidated through habeas corpus proceedings. Because the complaint was subject to dismissal on these grounds regardless of amendment, the court affirmed the district court’s decision to deny leave to amend without prejudice. The practical consequence is that Townes’s lawsuit seeking to invalidate his federal conviction and remove ongoing collateral consequences remains dismissed, and he must first successfully challenge his conviction through proper habeas proceedings before pursuing such civil relief. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.