Amicus Curiae Brief — Gabriel Olivier, Petitioner v. City of Brandon, Mississippi

Supreme Court briefSep 9, 2025

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No. 24-993

In the Supreme Court of the United States

GABRIEL OLIVIER,

Petitioner,

CITY OF BRANDON, ET AL.,

Respondents.

On Writ of Certiorari to the

United States Court of Appeals for the Fifth Circuit.

BRIEF OF YOUNG AMERICA’S

FOUNDATION AS AMICUS CURIAE

IN SUPPORT OF PETITIONER

Rachel A. Rickel

McMahon Surovik Suttle, P.C.

P.O. Box 3679

Abilene, TX 79604

Madison Leigh Hahn

Counsel of Record

Young America’s

Foundation

11480 Commerce Park

Dr., Ste 600

Reston, VA 20191

mhahn@yaf.org

(800) 872-1776

Counsel for Amicus Curiae

September 9, 2025

TABLE OF CONTENTS

Table of Authorities .................................................... ii

Interest of Amicus Curiae ........................................... 1

Summary of the Argument ......................................... 2

Argument ..................................................................... 3

I. Doctrines governing interplay between

federal and state courts support Olivier’s

access to federal courts. .................................. 3

A. The federal district court had a duty to

exercise its grant of jurisdiction by

deciding Olivier’s constitutional issue ........ 4

B. City of Houston proscribes abstention

in First Amendment facial challenges ....... 5

C. Principles of comity and federalism

proscribe abstention in a constitutional

question related to but not decided in a

prior state court proceeding ....................... 6

II. Principles of statutory interpretation

dictate availability of § 1983 whenever

habeas relief is unavailable .......................... 11

III.A § 1983 claim’s essential elements should

determine whether success necessarily

implies the invalidity of the conviction ........ 14

Conclusion .................................................................. 17

TABLE OF AUTHORITIES

Cases

Allen v. McCurry,

449 U.S. 90 (1980) ................................................7, 8

Arizonans for Official English v. Arizona,

520 U.S. 43 (1997) ....................................................9

City of Houston v. Hill,

482 U.S. 451 (1987), .........................................3, 5, 6

Colo. River Water Conservation Dist. v.

United States,

424 U.S. 800 (1976) ............................................3, 10

Expressions Hair Design v. Schneiderman,

581 U.S. 37 (2017) ....................................................6

Exxon Mobil Corp. v. Saudi Basic Indus. Corp.,

544 U.S. 280, 293 (2005) ..........................................4

Growe v. Emison,

507 U.S. 25 (1993) ....................................................7

Health & Hosp. Corp. v. Talevski,

599 U.S. 166 (2023) ................................................12

Heck v. Humphrey,

512 U.S. 477 (1994) ............................2, 3, 11, 13, 15

Lance v. Dennis,

546 U.S. 459 (2006) ..................................................4

Maleng v. Cook,

490 U.S. 488 (1989) ................................................12

McDonough v. Smith,

588 U.S. 109 (2019) ................................................16

iii

Middlesex Cnty. Ethics Comm. v.

Garden State Bar Ass’n,

457 U.S. 423 (1982) ..................................................8

New Orleans Pub. Serv., Inc., v.

Council of New Orleans,

491 U.S. 350 (1989) ..................................................8

Patsy v. Bd. of Regents of State of Fla.,

457 U.S. 496 (1982) ................................................12

Preiser v. Rodriguez,

411 U.S. 475 (1973) ......................................2, 12, 13

Quackenbush v. Allstate Ins. Co.,

517 U.S. 706 (1996) ..................................................9

Rose v. Lundy,

455 U.S. 509 (1982) ................................................12

Stenberg v. Carhart,

530 U.S. 914 (2000) ..................................................5

Susan B. Anthony List v. Driehaus,

573 U.S. 149 (2014) ..........................................16, 17

Whole Woman's Health v. Hellerstedt,

579 U.S. 582 (2016) ..................................................9

Statutes

28 U.S.C. § 1257...........................................................4

28 U.S.C. § 1738...........................................................8

28 U.S.C. § 2254.........................................................12

42 U.S.C. § 1983....................................... 11, 12, 13, 14

INTEREST OF AMICUS CURIAE1

Young America’s Foundation (“YAF”) is a national

nonprofit organization. A significant part of YAF’s

mission is to promote and support free speech by

college students, including by training journalists

through its National Journalism Center Over the last

45 years, the Center has trained over 2,250 budding

journalists to ethically and boldly exercise their First

Amendment rights and combat bias in the

mainstream media. YAF has a significant interest in

protecting those journalists’ First Amendment rights.

YAF is alarmed at the far-reaching effect and lack

of protection for claimants under the Fifth Circuit’s

expansion of the Heck bar. YAF files this brief out of

concern for its members’ ability to seek needed

prospective injunctive relief when faced with

violations of their constitutional rights, including the

right to free speech.

1 No counsel for a party authored this brief in whole or in part,

and no person other than amici and their counsel made any

monetary contribution intended to fund the preparation or

submission of this brief.

SUMMARY OF THE ARGUMENT

Federal courts have jurisdiction to consider

Petitioner Gabriel Olivier’s claim. In refusing to

exercise their jurisdiction, the courts below created a

de facto broad new abstention doctrine. But principles

of comity and federalism do not counsel abstention

here because Olivier raises a First Amendment

constitutional claim and because no state court is

considering or has already decided his claim. Thus,

this Heck expansion violates federal courts’

responsibility to adjudicate cases and controversies

within their jurisdiction.

The Heck bar’s original purpose was to harmonize

two conflicting statutes: the Civil Rights Act and the

federal habeas statute. Preiser v. Rodriguez, 411 U.S.

475 (1973); Heck v. Humphrey, 512 U.S. 477 (1994).

To achieve this harmonization, the Heck court tied the

test of “necessarily impl[ying] the invalidity” of a

conviction to the elements of the § 1983 claim. The

Heck bar has now escaped these confines, causing

confusion and harming claimants.

This Court should hold that the Heck bar does not

prevent a federal court from deciding the

constitutional question in a § 1983 claim when the

claimant cannot access federal habeas relief or when

the claimant seeks prospective relief on a claim that

does not require proof of the invalidity of his

conviction.

ARGUMENT

I. Doctrines governing interplay between

federal and state courts support Olivier’s

access to federal courts.

Federal courts have a “virtually unflagging

obligation . . . to exercise the jurisdiction given them,”

even when state courts hold concurrent jurisdiction.

Colo. River Water Conservation Dist. v. United States,

424 U.S. 800, 817 (1976) (citing England v. La. State

Bd. of Med. Exam’rs, 375 U.S. 411, 415 (1964);

McClellan v. Carland, 217 U.S. 268, 281–82 (1910);

Cohens v. Virginia, 19 U.S. 264 (1821)). Thus,

generally, “the pendency of an action in the state court

is no bar to [federal] proceedings concerning the same

matter.” Id. (quoting McClellan, 217 U.S. at 282)

(citing Donovan v. City of Dallas, 377 U.S. 408 (1964)).

The Fifth Circuit expanded the rule of Heck v.

Humphrey, 512 U.S. 477 (1994) to create in essence a

new abstention doctrine allowing it to refuse to decide

a question within its jurisdiction. This extension of

the Heck bar violates the principles of City of Houston

v. Hill, 482 U.S. 451 (1987), which disapproves of

abstention in First Amendment facial challenges such

as the one at issue here. The extension also violates

constitutional, legislative, and judicial doctrines that

control federal courts’ ability to hear constitutional

challenges. Thus, this Court should reverse.

A. The federal district court had a duty to

exercise its grant of jurisdiction by

deciding Olivier’s constitutional issue.

“Federal courts . . . have ‘no more right to decline

the exercise of jurisdiction which is given, than to

usurp that which is not given.’” Sprint Commnc’ns,

571 U.S. 69, 590–91 (2013) (quoting Cohens, 19 U.S.

264). The Rooker–Feldman doctrine addresses

jurisdictional boundaries related to the interplay

between federal and state courts. Lance v. Dennis, 546

U.S. 459, 463–64 (2006) (citing 28 U.S.C. § 1257).

Congress has reserved federal review of state court

judgments to this Court. 28 U.S.C. § 1257. Thus,

Rooker–Feldman prevents district courts from

adjudicating an attack on a state court judgment

brought by the state court party. Lance, 546 U.S. at

463–64. However, no jurisdictional bar exists for an

independent federal claim that involves similar

questions as in the state court. Exxon Mobil Corp. v.

Saudi Basic Indus. Corp., 544 U.S. 280, 293 (2005).

No jurisdictional bar applies here. Olivier does not

challenge his conviction or seek to overturn it; instead,

he brings an independent claim in federal court. Even

if Olivier’s § 1983 claim “denies a legal conclusion that

a state court has reached in a case to which he was a

party,” this fact does not deprive the federal district

court of jurisdiction. Id. (quoting GASH Assocs. v.

Rosemont, 995 F. 2d 726, 728 (7th Cir. 1993)) (citing

Noel v. Hall, 341 F.3d 1148, 1163–64 (9th Cir. 2003)).

The district court should have exercised jurisdiction.

B. City of Houston proscribes abstention

in First Amendment facial challenges.

Olivier initiated this federal case asserting that

the City’s ordinance, which creates a “designated

protest area” that negates his ability to communicate,

violates the First Amendment. Joint Appx. 1–2, 6–7.

Olivier petitioned the district court for “prospective

injunctive relief . . . on grounds of facial

unconstitutionality.” Petition Appx. 9a. This is exactly

the type of adjudication from which federal courts

should not abstain. City of Houston, 482 U.S. at 453,

467–68 (first quoting Dombrowski v. Pfister, 380 U.S.

479, 489–90 (1965); and then quoting Zwickler v.

Koota, 389 U.S. 241 (1967)).

When, as here, a plaintiff brings a First

Amendment challenge to an unambiguous municipal

ordinance, “there is certainly no need for a federal

court to abstain.” Id. at 455, 469–70; see also Stenberg

v. Carhart, 530 U.S. 914, 945 (2000) (confirming the

City of Houston rule). Even if a statute may contain

ambiguity, the fact that a municipality has previously

applied the statute satisfies any federalism or comity

concerns by showing that the state court had a fair

opportunity to limit the scope of the ordinance and

failed to do so. City of Houston, 482 U.S. at 468–70.

The Fifth Circuit’s refusal to provide a federal

forum has “itself effect[ed] the impermissible chilling

of the very constitutional right [Olivier] seeks to

protect.” See City of Houston, 482 U.S. at 467–68

(quoting Zwickler, 389 U.S. at 252). This result stands

contrary to City of Houston’s express instructions.

To avoid such chilling, federal courts should not

abstain from deciding a First Amendment facial

challenge. Id; see also Expressions Hair Design v.

Schneiderman, 581 U.S. 37, 58 (2017) (Sotomayer, J.,

concurring) (“this Court has described abstention as

particularly problematic where, as here, a challenge

to a state statute rests on the First Amendment”)

(citing Virginia v. Am. Booksellers Assn., Inc., 484

U.S. 383, 396 (1988); City of Houston, 482 U.S. at 467–

68)). Thus, reversal is warranted to avoid chilling the

First Amendment rights—including the rights of

amicus’s members.

C. Principles of comity and federalism do

not allow a federal court to abstain

from a constitutional question related

to but not decided in a prior state court

proceeding.

Federal courts and state courts often exercise

concurrent jurisdiction over the same subject matter.

Growe v. Emison, 507 U.S. 25, 32 (1993). Such parallel

proceedings do not ordinarily require a federal court

to dismiss or stay the federal action. Id. “In rare

circumstances, however, principles of federalism and

comity dictate otherwise.” Id.

The claim preclusion doctrine and various

abstention doctrines address whether a federal court

should dismiss, stay, or alter a federal proceeding in

deference to a related state court proceeding. Allen v.

McCurry, 449 U.S. 90, 95–96 (1980) (preclusion);

Growe, 507 U.S. at 32 (1993) (abstention). However,

as discussed below, federal courts need not dismiss a

claim in deference to the state judicial system when

the state proceeding is complete or if a claimant

requires a federal forum to litigate a constitutional

issue. This Court warns against overuse of abstention

out of concern that claimants maintain access to

federal courts for redress for constitutional violations.

First, the Younger abstention doctrine can prohibit

federal courts from enjoining ongoing state

prosecutions or similar proceedings. Sprint

Commc’ns, 571 U.S at 72–73 (citing New Orleans Pub.

Serv., Inc. v. Council of New Orleans, 491 U.S. 350,

358 (1989); Huffman v. Pursue, Ltd., 420 U.S. 592

(1975)) (applying doctrine of Younger v. Harris, 401

U.S. 37 (1971)). But outside of these “exceptional”

circumstances, the “general rule governs” and no bar

exists. Id. at 73 (quoting Colo. River, 424 U.S. at 817).

And regardless of the pendency of a state court

proceeding, courts should not apply Younger when the

claimant lacks adequate opportunity to raise a

constitutional challenge in the state court proceeding.

Middlesex Cnty. Ethics Comm. v. Garden State Bar

Ass’n, 457 U.S. 423, 432 (1982) (affirmed as factor in

the Younger analysis by Sprint Commnc’ns, 571 U.S.

at 81).

When Olivier filed his § 1983 claim, no state court

proceeding was pending. Petition Appx. 3a. Moreover,

Olivier’s claim consists of a constitutional challenge.

Thus, this Court should open the federal courthouse

doors to Olivier and decide his constitutional question.

Depriving Olivier of access to federal courts “make[s]

a mockery of the rule that only exceptional

circumstances justify a federal court’s refusal to

decide a case in deference to the States.” New Orleans

Pub. Serv., Inc., 491 U.S. at 368 (citing Colo. River,

424 U.S. at 817; Moses H. Cone Memorial Hospital v.

Mercury Construction Corp., 460 U.S. 1, 25 (1983);

Moore v. Sims, 442 U.S. 415, 423 n.8 (1979)).

Additionally, under claim preclusion, when a state

court has already decided a question and the same

party attempts to relitigate the same claim at a

federal court, the federal court must give “full faith

and credit” to the prior state court decision—to the

same extent that the state court would do so. Allen,

449 U.S. at 96 (quoting 28 U.S.C. § 1738). However,

claim preclusion does not prohibit a federal court from

independently deciding a subsequent claim based on

the same subject matter when the federal claim is not

the “very same claim” as brought in state court, even

if the distinction is minute or nuanced. Whole

Woman's Health v. Hellerstedt, 579 U.S. 582, 599, 601,

(2016), as revised (June 27, 2016), abrogated on other

grounds by Dobbs v. Jackson Women's Health Org.,

597 U.S. 215 (2022).

Moreover, when a federal court is presented with

an unclear, undecided, complex question of state law,

the federal court may either apply the Burford

abstention (for “difficult questions of state law bearing

on policy problems of substantial public import”) or

certify the question to the state court to gain

clarification on the state law issue. Quackenbush v.

Allstate Ins. Co., 517 U.S. 706, 726–27 (1996) (quoting

New Orleans Pub. Serv., 491 U.S. at 361) (Burford

abstention); Arizonans for Off. Eng. v. Arizona, 520

U.S. 43, 75–76 (1997) (discussing certification as

successor to historical Pullmanabstention);.

Olivier’s position is inapposite to a claim in which

a federal court would need to defer to (or wait for) a

state court’s holding. Olivier does not ask the federal

courts to reexamine his conviction; thus, he does not

seek to relitigate the “very same issue.” The state

court never decided—nor was it asked to decide—the

issue that Olivier brings to federal court: the

constitutionality of the ordinance. And the state court

never made a ruling related to the prospective

equitable relief that Olivier seeks. Moreover, the state

courts have already interpreted and applied the

ordinance to Olivier and others, so the federal court is

well apprised of the state court’s position on the

ordinance. As a result, the principles which counsel

deference through preclusion, certification, or Burford

abstention simply don’t apply. Instead, because

Olivier’s § 1983 claim has a federal basis for

jurisdiction, it was inappropriate for the federal

district court to abdicate its duty to exercise its

jurisdiction. Colo. River, 424 U.S. at 815 n.21 (citing

Burford v. Sun Oil Co., 319 U.S. 315, 318 n.5 (1943);

Hawks v. Hamill, 288 U.S. 52, 61 (1933)).

In sum, each of the above doctrines counsels a

federal court to refrain from making a decision

because a state court has decided, is deciding, or will

decide that question. The Fifth Circuit created a “Heck

abstention” to avoid a question that a state court has

not decided, is not deciding, and will not decide. Thus,

far from applying principles of comity, equity, and

federalism to shepherd the question to the most

appropriate forum, this new “Heck abstention”

deprives a litigant of any resolution to his

constitutional claim.

When a federal court would decline to exercise its

jurisdiction, “[o]nly the clearest of justifications will

warrant dismissal.” Colo. River, 424 U.S. at 819. No

such justification appears here.

Olivier’s question is squarely within the federal

courts’ jurisdiction. Principles of comity and

federalism do not reveal any need for deference to the

state courts. Thus, this Court should hold that the

federal courts must follow their “virtually unflagging

obligation” to decide the federal question Olivier

brings. See Sprint Commnc’ns, 571 U.S. at 591

(quoting Colo. River, 424 U.S. at 817).

II.Principles of statutory interpretation

dictate availability of § 1983 whenever

habeas relief is unavailable.

Heck and its predecessor attempted to address the

“collision course” between § 1983 and federal habeas

statutes and to harmonize them. Heck v. Humphrey,

512 U.S. 477, 491 (1994) (Thomas, J., concurring). The

Fifth Circuit’s approach does not attempt such

harmonization. This Court should require lower

courts to apply principles of statutory construction to

properly construe and harmonize these statutes.

Congress established the Civil Rights Act of 1871,

now codified in 42 U.S.C. § 1983, to give plaintiffs

broad access to federal courts to obtain relief from

constitutional injuries. Mitchum v. Foster, 407 U.S.

225, 242 (1972). The statute’s plain language

“reflect[s] the regrettable reality that ‘state

instrumentalities’ could not, or would not, fully

protect federal rights.” Health & Hosp. Corp. v.

Talevski, 599 U.S. 166, 177 (2023) (quoting Mitchum,

407 U.S. at 240 (1972)). Consistent with its purpose,

Section 1983 does not require plaintiffs to first

exhaust state administrative remedies. Patsy v. Bd. of

Regents, 457 U.S. 496, 502, 506 (1982).

The federal habeas statute provides another

avenue for a narrow group of petitioners to obtain a

narrow type of relief from constitutional injuries

through federal courts. 28 U.S.C. § 2254. Habeas

relief is available only to custodial prisoners who seek

to attack the conviction or sentence that they are then

serving, Maleng v. Cook, 490 U.S. 488, 490 (1989)

(citing Carafas v. LaVellee, 391 U.S. 234, 238 (1968)),

and only after a petitioner exhausts all avenues of

relief in state courts, Rose v. Lundy, 455 U.S. 509, 515,

518–19 (1982) (holding exhaustion rule is based on

principles of federalism and comity).

Prisoners have attempted to use § 1983 as a type

of loophole to avoid the habeas prerequisites while

still obtaining habeas-like relief from their sentence.

See, e.g., Preiser v. Rodriguez, 411 U.S. 475, 479 (1973)

(discussing prisoner’s civil rights suit that was “really

a petition for habeas corpus”). This pathway would

have the practical effect of nullifying Congress’s

expressed intent for prisoners to exhaust

administrative remedies before obtaining relief from

the fact or duration of their sentence.

In Preiser, the precursor to Heck, this Court closed

this prisoner loophole by applying the principle of

statutory interpretation that the specific controls over

the general. Id. at 489–90. Although the plain

language of § 1983 would ostensibly allow custodial

prisoners to attack the fact or duration of their

confinement, Preiser carved this type of claim—the

realm of the more specific habeas statute—out of the

claims available under the more generalized § 1983

statute. Id. This Court’s analysis focused on

harmonizing both statutes and giving meaning to

each. Id. (“It would wholly frustrate explicit

congressional intent to hold that the respondents in

the present case could evade this [administrative

exhaustion] requirement by the simple expedient of

putting a different label on their pleadings.”).

Heck to some degree continued to apply the rule of

statutory interpretation that the specific (habeas)

controls the general (§ 1983) by requiring prisoners

who were “attacking . . . the fact or length

of . . . confinement” to adhere to the same threshold

showing as the habeas statute: favorable termination.

Id. at 481–82, 487. However, subsequent applications

of the Heck bar have drifted from the original

underpinnings of harmonization and statutory

construction. This is particularly apparent in the

Fifth Circuit’s holding, which bars a claim to which

habeas never would have applied. Thus, courts have

moved far afield of merely closing the prisoner

loophole and enforcing the administrative exhaustion

requirement of habeas statutes for custodial prisoners

attacking their confinement.

This Court should construe § 1983 and habeas

statutes in harmony and limit the Heck bar only to

claims in which habeas relief is available. A litigant

who cannot access habeas relief should have access to

federal courts through § 1983.

III.A § 1983 claim’s essential elements should

determine whether success necessarily

implies the invalidity of the conviction.

The opinion below—and much of the Heck

progeny—focus on determining whether the plaintiff’s

claim, if successful, “necessarily impl[ies] the

invalidity” of a conviction. Petition Appx. 7a–91, 11a,

14a (quoting Heck, 512 U.S at 487). However, Heck

required this analysis only “when a state prisoner

seeks damages in a § 1983 suit.” Heck, 512 U.S. at 487.

Because Olivier is not (and never was) a state prisoner

and does not seek damages, this analysis does not

apply to him. However, if this Court decides to engage

in the analysis of whether Olivier’s claim, if

successful, would necessarily imply the invalidity of

his conviction, this Court should tie the analysis to the

essential elements of the claim.

In Heck, this Court identified the § 1983 claim as

a malicious prosecution suit. 512 U.S. at 484. As an

essential element of, the plaintiff needed to prove that

he had received a criminal conviction, but that his

conviction terminated in his favor through reversal,

expungement, or other declaration of invalidity. Id. at

484, 486–87. Thus, if the plaintiff “establish[ed] the

basis for the damages claim” he would have

“necessarily demonstrate[d] the invalidity of the

conviction.” Id. at 481–82. This Court barred “[a]

claim for damages bearing that relationship to a

conviction or sentence.” Id. at 487 (emphasis added).

In this immediate context, the Court stated:

“Thus, when a state prisoner seeks damages in

a § 1983 suit, the district court must consider

whether a judgment in favor of the plaintiff

would necessarily imply the invalidity of his

conviction or sentence; if it would, the

complaint must be dismissed unless the

plaintiff can demonstrate that the conviction or

sentence has already been invalidated.”

Id. (emphasis added).

The Heck court thus tied the test of “necessarily

imply[ing] the invalidity of [a] sentence” to the

elements of a claim, holding that the claim and

sentence must bear the same type of relationship as

in Heck. A successful § 1983 claim does not imply the

invalidity of a conviction unless an essential element

of the § 1983 cause of action requires the plaintiff to

prove the facts of his prior conviction and its

invalidity. Id. at 486 n. 6, 487 n. 7. For this reason, the

Heck bar analysis “depends on what facts a § 1983

plaintiff would need to prove to prevail on his claim.”

McDonough v. Smith, 588 U.S. 109, 126 (2019)

(Thomas, J., dissenting). A court cannot determine

whether the Heck bar applies to a § 1983 claim until

it determines and examines the elements of the claim.

Olivier does not bring a malicious prosecution

claim. Olivier’s claim does not require him to prove

any facts relating to any prior conviction—because it

does not require that a plaintiff hold a prior conviction

at all. Susan B. Anthony List v. Driehaus, 573 U.S.

149, 158–59 (2014). A plaintiff can successfully bring

a facial constitutional challenge to a statute without

mentioning that he committed acts prohibited by the

statute, or whether he was charged, prosecuted,

convicted, or sentenced under the statute. Id. at 158

(citing Steffel v. Thompson, 415 U.S. 452, 459 (1974)

(“an actual arrest, prosecution, or other enforcement

action is not a prerequisite to challenging the law.”).

Although a plaintiff could use the facts of his

conviction to establish standing, for example to show

imminent harm or the presence of an actual

controversy, a prior conviction is still not necessary

even for this threshold determination. Id.

If the Court reaches this analysis, it should hold

that a claim necessarily implies the invalidity of a

conviction only when an essential element of the

§ 1983 claim requires proof of the existence and

invalidity of a conviction. Because Olivier’s claim does

not require this proof, it does not necessarily imply his

conviction’s invalidity, so Heck does not bar the claim.

CONCLUSION

Federal courts have an obligation to decide cases

and controversies over which they hold jurisdiction—

including cases such as Olivier’s. This Court should

reverse the Fifth Circuit’s holding because principles

of comity and federalism do not warrant abstention.

Instead, this Court should harmonize § 1983 and

habeas statutes, limit Heck to its original context, and

hold that Heck does not bar Olivier’s claim.

Respectfully submitted,

Madison Leigh Hahn,