United States District Court, M.D. Louisiana
RULING AND ORDER
A. JACKSON UNITED STATES DISTRICT JUDGE.
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.
excessive-force case arises from a scuffle between prison
guards and an inmate. (Doc. 13).
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.
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).
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.
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).
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).
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).
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)
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