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Jacobs v. Wells

United States District Court, M.D. Louisiana

August 29, 2019




         Before 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 is GRANTED.

         I. BACKGROUND

         This 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.

         Defendants 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.


         A. Summary Judgment

         Summary 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 omitted).

         In 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. 1994)).

         In sum, 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).

         B. Heck v. Humphrey

         The 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).


         In 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 ...

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