Steps to reproduce:

• enabled 'Require JIRA issue key for a successful commit' at host/secure/admin/SvnCommitHooks.jspa.
• make a commit against SVN while referencing a Closed ticket with the following commit message:
  issuekey-911 #reopen blahblah

errors:

maleko:XYZ mtaylor$ svn commit -m "XYZ-1 #reopen blahblah"
Adding         good.txt
Transmitting file data .svn: Commit failed (details follow):
svn: Commit blocked by pre-commit hook (exit code 1) with output:
Issue XYZ-1 is not open