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Aucoin v. Cupil

United States District Court, M.D. Louisiana

April 22, 2019

LAYNE AUCOIN
v.
ANDREW CUPIL ET AL.

          RULING AND ORDER

          BRIAN A. JACKSON UNITED STATES DISTRICT JUDGE.

         Before the Court is Layne Aucoin1 s Motion to Alter or Amend (Doc. 83) the final judgment dismissing his suit with prejudice under Heck v. Humphrey, 512 U.S. 477 (1994). For the reasons that follow, the Motion (Doc. 83) is GRANTED IN PART and DENIED IN PART.

         I. BACKGROUND

         This excessive-force case arises from a scuffle between prison guards and an inmate. (Doc. 13).

         Layne Aucoin is an inmate who was incarcerated at Dixon Correctional Institute in Jackson, Louisiana. (Id.). Andrew Cupil and Reginald Robinson are guards at Dixon Correctional Institute. (Id.). Aucoin sued them under Louisiana Civil Code Article 2315 and 42 U.S.C. § 1983 for using excessive force against him. (Id.). He alleges that Cupil and Robinson sprayed him with mace and then kicked and punched him when he was restrained. (Id.).

         The incident happened on August 24, 2015. (Doc. 13 at ¶ 5). That morning, Aucoin was in his cell on suicide watch. (Id. at ¶ 7). Around 11:00 A.M., he placed a cup over a video camera in his cell. (Id.). He alleges that Cupil and Robinson then "snuck up" on him, sprayed him with mace, and beat him after restraining him. (Id. at ¶ 8).

         The next day, the prison issued disciplinary reports. (Docs. 33-13, 33-14). The reports charge Aucoin with defiance, aggravated disobedience, and destruction of property. (Id.). The reports reflect that Aucoin disobeyed Robinson's direct order to uncover the cell camera, spat on Robinson, and yelled expletives at Robinson and Cupil. (Id.). The reports also reflect that Aucoin was convicted of the charges after a hearing and that the convictions cost him 30 days of good-time credit. (Id.).

         Pointing to the convictions, Cupil and Robinson moved to dismiss Aucoin's claims under Heck. (Doc. 78). They argued that success on Aucoin's claims would "necessarily imply the invalidity" of his convictions. (Doc. 78-1). The Court agreed and granted the motion. (Doc. 81).

         The Court's ruling focused on the use of mace. (Id.). The Court reasoned that Aucoin's excessive-force claim was Heck-barred because a finding that Cupil and Robinson used mace "maliciously and sadistically" would "necessarily imply the invalidity" of his convictions-convictions that showed the use of mace to be a "good-faith effort to maintain or restore discipline." (Id.) (citing Heck, 512 U.S. at 847). The Court concluded that Aucoin's negligence claim, too, was Hecfe-barred. (Id.). A finding that Cupil and Robinson acted unreasonably when they sprayed Aucoin with mace, the Court reasoned, would contradict the factual findings incorporated into the disciplinary convictions and thus "necessarily imply the[ir] invalidity." (Id.). Because the Court concluded that Aucoin's claims were Hecfc-barred, the Court dismissed them with prejudice and entered judgment for Cupil and Robinson. (Docs. 81, 82).

         Aucoin moves the Court to alter or amend the judgment under Federal Rule of Civil Procedure 59(e). (Doc. 83). Cupil and Robinson oppose. (Doc. 84).

         II. LEGAL STANDARD

         A party may move to alter or amend a judgment no more than 28 days after the entry of judgment. Fed. R. Crv. P. 59(e). A motion to alter or amend a judgment must "clearly establish either a manifest error of law or fact or must present newly discovered evidence." Lamb u. Ashford Place Apartments, L.L.C., 914 F.3d 940, 943 (5th Cir. 2019) (citation omitted).

         III. DISCUSSION

         A plaintiff cannot "recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction invalid," unless he "prove[s] that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into ...


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