# Echols

> District Court, W.D. Arkansas · April 6, 2026

URL: https://www.frixlaw.com/law-library/cases/11305763

## Case

- **Full name:** Waylon Lee Echols v. Arkansas Post Prison Transfer Board; Arkansas Parole Board; Lona H. McCastlain; and John Felts
- **Court:** District Court, W.D. Arkansas
- **Decided:** April 6, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

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- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11305763

## Opinion text

IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
FAYETTEVILLE DIVISION

WAYLON LEE ECHOLS PLAINTIFF

V. CASE NO. 5:26-CV-5023

ARKANSAS POST PRISON
TRANSFER BOARD;
ARKANSAS PAROLE BOARD;
LONA H. MCCASTLAIN;
and JOHN FELTS DEFENDANTS

ORDER
Before the Court is a Report and Recommendation (“R&R”) (Doc. 9) by United
States Magistrate Judge Christy Comstock, recommending that Plaintiff Waylon Lee
Echols’s original Complaint (Doc. 1) be dismissed without prejudice on preservice
screening under 28 U.S.C. § 1915A for failure to state a claim on which relief can be
granted. Mr. Echols did not file objections to the R&R. Instead, he filed an Amended
Complaint (Doc. 12). The Amended Complaint eliminates separate claims against the
Arkansas Parole Board and John Felts but maintains claims against the Arkansas Post
Prison Transfer Board and Lona H. McCastlain in her individual capacity.
According to both the original and amended Complaints, Mr. Echols asserts that
he was arrested on charges that formed the basis for revoking his parole two weeks later.
Though these underlying charges were nolle prossed, Mr. Echols was still convicted for
violating his parole. The Amended Complaint explains that Mr. Echols appealed the parole
revocation to Ms. McCastlain, the Chairman of the Parole Board, but she affirmed the
revocation decision. Nevertheless, Mr. Echols maintains that his constitutional rights were
violated when his parole was revoked and he was denied a fair hearing.
The R&R explains that under Heck v. Humphrey, 512 U.S. 477, 486–87 (1994):
in order to recover damages for allegedly unconstitutional conviction or
imprisonment, or for other harm caused by actions whose unlawfulness
would render a conviction or sentence invalid, a § 1983 plaintiff must prove
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 also applies to claims that imply the invalidity of a parole revocation. See Newmy v.
Johnson, 758 F.3d 1008, 1011–12 (8th Cir. 2014). In the case at bar, Mr. Echols has not
alleged in either his original or amended Complaint his parole revocation was reversed,
expunged, declared invalid, or called into question by issuance of a writ of habeas corpus.
The claims in both pleadings are Heck-barred.
IT IS THEREFORE ORDERED that the R&R (Doc. 9) is ADOPTED IN ITS
ENTIRETY, the case is DISMISSED WITHOUT PREJUDICE for failure to state a claim,
and Plaintiff is warned that, in the future, this dismissal may be counted as a strike for
purposes of 28 U.S.C. § 1915(g). Thus, the Clerk is directed to place a § 1915(g) strike
flag on the case for future judicial consideration.
IT IS SO ORDERED on this 6th day of April, 2026.
/s/ Timothy L. Brooks

TIMOTHY L. BROOKS
CHIEF UNITED STATES DISTRICT JUDGE

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11305763. Public record. Not legal advice.