Opinion

Jacobs v. Wells

Court
District Court, M.D. Louisiana
Filed
Sep 3, 2019
Cited by
0 cases
Authority
More cited than 22.5%

The opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

JONATHAN JACOBS CIVIL ACTION

VERSUS

CAPTAIN JOHN WELLS AND NO: 16-CV-00865-BAJ-EWD

LIEUTENANT MICHAEL W. COLLINS.

RULING AND ORDER

Before the Court is Defendants’ Motion for Summary Judgment (Doe, 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. Ud. at 4] 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.

dd. at § 9). Plaintiff alleges that he suffered from a broken ankle and leg as a result

of the alleged beating. Ud. at 15). Plaintiff now brings claims against Defendants

under 42 U.S.C. § 1988.

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. Ud.). Plaintiff ultimately lost a total of 120 days of good

time credit, 12 weeks of canteen privileges, and 12 weeks of yard privileges. (/d. 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.

II. LEGAL STANDARD

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]Is] all

reasonable inferences in her favor.” Coleman v. Houston Indep. Sch. Dist., 118 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. 817,

322 (1986). Summary judgment will he 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 jadgment 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 (19865).

Ti. DISCUSSION

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 § 1988 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 situation the Heck Court sought to prevent. Plaintiff makes this exact claim in his

Complaint when he alleges:

[i]t was unreasonable for Defendant(s) to use force on Plaintiff when he

was not resisting and when he was no longer resisting or attempting to

flee, or otherwise, commit any crime. Use of force was unnecessary and

excessive to any need and/or there was no need for use of force under the

4th and 8th Amendments and the circumstances presented.

A finding that Plaintiff did “nothing wrong” would necessarily undermine the result

of the disciplinary proceedings wherein Plaintiff was found to have committed certain

acts that resulted in the loss of certain privileges, even if it was not Plaintiffs intent

to upset these findings. Plaintiff cannot now attempt to re-argue matters that were

already resolved in the disciplinary proceeding by way of the instant § 1983 claim.

Therefore, even when all inferences are made in Plaintiffs favor, absent some

indication that the results of the disciplinary proceedings have already been deemed

to have been improperly reached, Plaintiffs claim is barred by Heck.

IV. CONCLUSION

Accordingly,

IT IS ORDERED that Defendants’ Motion for Summary Judgment

(Doc. 74) is GRANTED.

Baton Rouge, Louisiana, this a te of August, 2019.

Aue.

JUDGE ~2> JACKSON

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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