Fifth Circuit Reinstates Louisiana Prisoner’s Excessive-Use-of-Force Claim
On May 6, 2020, the Fifth Circuit court of appeals reversed the summary dismissal of Louisiana prisoner Layne Aucoin’s claim that state prison guards used excessive force after he was restrained and compliant following an altercation with guards. The appellate court upheld the dismissal of his claim that excessive force was used during the altercation.
According to the opinion, a prison disciplinary report stated that Aucoin blocked the surveillance camera in his cell and disregarded guards’ repeated, direct orders to unblock it while screaming profanities at them. He also tried to use a paper gown to block a sink drain so he could flood his cell and spit at a guard. Guards then sprayed a one-second burst of a chemical agent into his cell before entering it and restraining him. He was later found guilty of disciplinary infractions for defiance, aggravated disobedience and destruction of property.
According to Aucoin, after he was restrained and compliant, guards took him to a shower where the “maced” him and then to the prison lobby where they beat him and kicked him. He filed a federal civil rights action pursuant to 42 U.S.C. § 1983, alleging guards used excessive force in his cell, the shower and the lobby.
The district court dismissed all of Aucoin’s claims as being barred by Heck v. Humphrey, 512 U.S. 477 (1994). Aucoin appealed.
The Fifth Circuit held that a prisoner “cannot bring a § 1983 claim for excessive use of force by a prison guard, if the prisoner has already been found guilty of misconduct that justified that use of force. But Heck does not bar a § 1983 claim for a prison guard’s excessive use of force after the inmate has submitted and ceased engaging in the alleged misconduct.” Thus, the district court rightly dismissed the claim based on the guards' use of force in Aucoin’s cell, but erred when it dismissed the claims based on their use of force in the shower and lobby.
Therefore, the appellate court reversed the dismissal of Aucoin’s claim and remanded the case for further proceedings. See: Aucoin v. Cupil, 5th Cir., No. 19-30779
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Related legal case
Aucoin v. Cupil
| Year | 2020 |
|---|---|
| Cite | 5th Cir., No. 19-30779 |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |