Peter Taylor v. R. Sanders
536 F. App'x 200 (2013)
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Rule of Law:
An inmate's Eighth Amendment excessive force claim will fail if the force used was de minimis and not repugnant to the conscience. Additionally, under the doctrine from Heck v. Humphrey, a Bivens claim for damages is barred if its success would necessarily invalidate a prison disciplinary action that resulted in the loss of good-conduct time, unless that disciplinary action has been overturned.
Facts:
- Peter Taylor was an inmate at the United States Penitentiary-Canaan (USP-Canaan).
- Appellees were employees at USP-Canaan.
- Taylor alleged that one of the Appellees, Officer Sanders, pushed and punched him in the back.
- Taylor lodged a complaint against Sanders for this alleged use of force.
- In November 2010, Appellees filed an incident report against Taylor, alleging he made sexual proposals or threats to another employee, Appellee Salzameda.
- Following a disciplinary hearing based on the November 2010 report, Taylor was found to have committed the violation.
- As a sanction for the violation, Taylor was forced to forfeit good-conduct time.
Procedural Posture:
- Peter Taylor filed a Bivens complaint against prison employees (Appellees) in the United States District Court for the Middle District of Pennsylvania, the federal trial court.
- Appellees filed a motion to dismiss and, in the alternative, a motion for summary judgment.
- The District Court granted the motion to dismiss in part, dismissing claims against Appellees in their official capacities and a claim for verbal harassment.
- The District Court then granted summary judgment in favor of the Appellees on Taylor's remaining claims for excessive force and retaliation.
- Peter Taylor (Appellant) appealed the grant of summary judgment to the United States Court of Appeals for the Third Circuit, an intermediate federal appellate court.
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Issue:
Does a prison official's use of de minimis force, such as a push and a punch, violate an inmate's Eighth Amendment rights, and is an inmate's retaliatory fabrication claim barred when a finding in his favor would invalidate a disciplinary conviction that has not been overturned?
Opinions:
Majority - Per Curiam
No, a prison official's use of de minimis force that is not repugnant to the conscience does not violate the Eighth Amendment. Yes, an inmate's retaliatory fabrication claim is barred if it would invalidate a standing disciplinary conviction. The court agreed with the District Court that even if Sanders used the force Taylor alleged, it was de minimis and did not rise to the level of a constitutional violation under the standard set in Hudson v. McMillian. Regarding the retaliation claim, the court applied the principles of Heck v. Humphrey and Edwards v. Balisok, concluding that since Taylor's disciplinary hearing resulted in the loss of good-conduct time, a successful Bivens action alleging the report was fabricated would necessarily imply the invalidity of his disciplinary conviction and the resulting loss of good time credits. Because this disciplinary conviction had not been overturned, his claim for damages was not cognizable. The court also rejected Taylor's attempt to introduce a claim based on a separate, dismissed February 2011 incident report, as it was not properly raised in his initial complaint and a plaintiff may not amend a complaint through arguments in a brief opposing summary judgment.
Analysis:
This case serves as a straightforward application of two significant barriers to prisoner civil rights litigation. First, it reinforces the high threshold for Eighth Amendment excessive force claims, clarifying that minor or de minimis uses of force without significant injury are unlikely to be considered unconstitutional. Second, it illustrates the potent procedural bar of the Heck v. Humphrey doctrine, which prevents prisoners from using civil rights lawsuits as a collateral attack on their convictions or, as here, on prison disciplinary proceedings that affect the duration of their confinement. The ruling emphasizes that prisoners must first succeed in having such disciplinary actions invalidated through proper channels (like administrative appeals or habeas corpus) before they can seek monetary damages for alleged constitutional violations related to those actions.
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