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Aucoin v. Cupil

United States District Court, M.D. Louisiana

August 26, 2019

LAYNE AUCOIN
v.
ANDREW CUPIL ET AL.

          RULING AND ORDER

          BRIAN A. JACKSON JUDGE

         Before the Court is Master Sergeant Reginald Robinson and Lieutenant Andrew Cupil's Motion for Reconsideration (Doc. 101) of the Court's Ruling and Order (Doc. 90) granting in part and denying in part Plaintiff Layne Aucoin's Motion to Alter or Amend Judgment (Doc. 83). For the reasons that follow, the Motion (Doc. 101) is GRANTED.

         I. BACKGROUND

         This case turns on the application of Heck v. Humphrey, 512 U.S. 477 (1994), to the excessive-force claims of a prisoner who insists guards restrained and then beat him for no reason. Again, he maintains he did nothing wrong. But his prison disciplinary convictions suggest otherwise. Because success on his claims would necessarily imply the invalidity of his convictions, Heck bars his claims.

         Heck precludes a plaintiff from "recovering] 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 question by a federal court's issuance of a writ of habeas corpus." Heck, 512 U.S. at 486-487. The doctrine applies to prison disciplinary convictions. Edwards v. Balisok, 520 U.S. 641, 646-48 (1997). It does not, however, apply to "a prisoner's challenge that threatens no consequence for his [underlying] conviction or the duration of his sentence." Muhammad v. Close, 540 U.S. 749, 751 (2004) (per curiam).

         Plaintiff Layne Aucoin is an inmate who was incarcerated at Dixon Correctional Institute in Jackson, Louisiana. (Doc. 13). Master Sergeant Robinson and Lieutenant Cupil 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, in particular, that they sprayed him with mace and then kicked and punched him after he was restrained. (Id.).

         On the morning of trial, Defendants invoked Heck and moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).[1] (Doc. 78). Defendants contended that Aucoin's claims were Hec/e-barred because Aucoin received disciplinary convictions[2] for his role in the incident giving rise to this lawsuit. (Doc. 78-1 at p. 1-8). Defendants stressed that success on Aucoin's claims would "necessarily imply the invalidity" of his disciplinary convictions. (Id. at p. 4). The Court agreed and entered judgment against Aucoin. (Doc. 81).

         Thereafter, Aucoin moved to alter or amend the judgment. (Doc. 83-2 at pp. 1- 14). He contended Heck did not apply because he did not seek restoration of the good-time credits he lost as a result of his disciplinary convictions. (Id.). The Court found the contention meritless[3] but granted the motion, in part, based on new authority not cited by either party. (Doc. 90 at p. 4) (citing Bourne v. Gunnels, 921 F.3d 484 (5th Cir. 2019)).

         In the Ruling and Order, the Court found that Aucoin alleged two distinct claims of excessive force: one arising from the use of mace and another arising from the use of force post-restraint. (Doc. 90 at pp. 1-7). Citing Bourne, the Court held that the former claim was Heck-barred but the latter was not. (Id.). The Court thus reinstated the latter claim. (Id.).

         Now, Defendants move for reconsideration. (Doc. 101). They contend that Bourne is distinguishable and that Aucoin's trial testimony reflects one Heck-barred excessive-force claim deriving from one continuous encounter. (Doc. 101-1 at pp. 1-9). For the first time, Defendants direct the Court to authority establishing that Heck mandates dismissal because Aucoin testified that he is innocent of the conduct forming the basis of his convictions. (Id. at p. 4 n.12). Aucoin filed a two-page opposition; he cites no authority apart from Heck, and he addresses none of Defendants' arguments. (Doc. 102 at pp. 1-2). Instead, he declares that "[t]he prejudicial nature of the Heck rulings in this case should be reviewed by the Fifth Circuit and the Rulings at issue should be certified for appeal." (Id. at p. 2).

         II. LEGAL STANDARD

         The Court may reconsider its rulings on an interlocutory order for "any reason it deems sufficient, even in the absence of new evidence or an intervening change in or clarification of the substantive law." Saqui v. Pride Cent. America, LLC, 595 F.3d 206, 210-211 (5th Cir. 2010) (citation omitted). The Court's Ruling and Order on Aucoin's Motion to Alter or Amend Judgment is an interlocutory order because it did not adjudicate all claims or decide the rights and liabilities of all parties. FED. R. CIV. P. 54(b). Accordingly, the Court is free to reconsider the Ruling and Order for "any reason it deems sufficient." Saqui, 595 F.3d at 210.

         III. DISCUSSION

         Defendants contend the Court should reconsider its application of Bourne and find that all of Aucoin's claims are Heck-bamed. (Doc. 101). Defendants contend Bourne is distinguishable because the plaintiff admitted engaging in the conduct ...


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