United States District Court, M.D. Louisiana
RULING AND ORDER
A. JACKSON UNITED STATES DISTRICT COURT JUDGE.
the Court is Defendants' Motion for Summary
Judgment (Doc. 74). Plaintiff filed an opposition to
Defendants' Motion (Doc. 78-2). Oral argument is not
required. For the reasons set forth below, Defendants Motion
matter arises from allegations that Jonathan Jacobs
("Plaintiff) was subjected to excessive force by Captain
John Wells and Lieutenant Michael W. Collins (collectively,
"Defendants") while imprisoned at the Elayn Hunt
Correctional Center. (Doc. 1 at p. 2). Specifically,
Plaintiff alleges that on April 12, 2016, after a brief
exchange of profanities between himself and Lt. Collins,
Defendants sprayed Plaintiff with two different types of
chemical agents. (Id. at ¶¶ 6-8).
Plaintiff further avers that after he was sprayed, he was
removed from his cell in full restraints and brought to the
security offices, where Cpt. Wells turned off the lights and
began beating him. (Id. at ¶ 9). Plaintiff
alleges that he suffered from a broken ankle and leg as a
result of the alleged beating. (Id. at ¶ 15).
Plaintiff now brings claims against Defendants under 42
U.S.C. § 1983.
claim that Plaintiffs actions caused him to receive multiple
disciplinary charges, including two counts of
"Defiance," one count of "Aggravated
Disobedience," and one count of "Contraband."
(Doc. 74-1 at p. 2). Defendants assert that Plaintiff pleaded
not guilty to each of the disciplinary charges, but an
internal disciplinary board hearing resulted in a finding
that Plaintiff was in fact guilty of all of the alleged
violations. (Id.). Plaintiff ultimately lost a total
of 120 days of good time credit, 12 weeks of canteen
privileges, and 12 weeks of yard privileges. (Id. at
p. 3). Defendants now move for summary judgment in this
matter pursuant to the ruling of the Supreme Court of the
United States in Heck v. Humphrey, 512 U.S. 477
(1994) and Federal Rule of Civil Procedure 56.
judgment is appropriate "if the movant shows that there
is no genuine dispute as to any material fact and that the
movant is entitled to a judgment as a matter of law."
Fed.R.Civ.P. 56(a). "[W]hen a properly supported motion
for summary judgment is made, the adverse party must set
forth specific facts showing that there is a genuine issue
for trial." Anderson v. Liberty Lobby, Inc.,
477 U.S. 242, 250 (1986) (quotation marks and footnote
determining whether the movant is entitled to summary
judgment, the Court "view[s] facts in the light most
favorable to the non-movant and draw[s] all reasonable
inferences in her favor." Coleman v. Houston Indep.
Sch. Dist., 113 F.3d 528, 533 (5th Cir. 1997) (citing
Brothers v. Klevenhagen, 28 F.3d 452, 455 (5th Cir.
summary judgment is appropriate if, "after adequate time
for discovery and upon motion, [the non-movant] fails to make
a showing sufficient to establish the existence of an element
essential to that party's case, and on which that party
will bear the burden of proof at trial." Celotex
Corp. v. Catrett, 477 U.S. 317, 322 (1986). Summary
judgment will lie only "if the pleadings, depositions,
answers to interrogatories, and admissions on file, together
with affidavits if any, show that there is no genuine issue
as to any material fact, and that the moving party is
entitled to judgment as a matter of law." Sherman v.
Hallbauer, 455 F.2d 1236, 1241 (5th Cir. 1972).
Heck v. Humphrey
rule in Heck provides that to recover damages for an
allegedly unconstitutional conviction or imprisonment, a
§ 1983 plaintiff must prove that the underlying
conviction or sentence has been nullified. Heck, 512
U.S. 477. Heck has been expanded to encompass prison
disciplinary proceedings. Edwards, 520 U.S. at
646-48. Part of the Heck analysis requires a court
to determine if the prison discipline was justified. The
standard of proof required for the revocation of good time
credit is exceptionally low. The Supreme Court has determined
that to meet Constitutional standards, "some
evidence" must be offered, even if it might be
characterized as "meager." Superintendent v.
Hill, 472 U.S. 445, 454 (1985).
light of the exceedingly low evidentiary standard for the
imposition of prison disciplinary procedures, allegations
that a prisoner "did nothing wrong" are fatal to a
prisoner's § 1983 claims because in such a
circumstance no adverse prison disciplinary action
would be justified. A finding that no discipline was
justified is by default a collateral attack on the
disciplinary procedure levied against the prisoner, a