Moffett v. Benefield

Background

Andrew L. Moffett, proceeding without a lawyer and described by the court as a prisoner, sued correctional officer J. Benefield under 42 U.S.C. § 1983. Moffett alleged that Benefield falsely accused him of assaulting another prisoner after a March 17, 2016 riot at Salinas Valley State Prison. Moffett alleged that the accusation led to a disciplinary proceeding, the loss of good-time credits, and a ten-month term in the Special Housing Unit.

The operative complaint asserted a due-process claim. The court had previously explained that false disciplinary charges generally are not actionable, but it construed Moffett’s complaint as alleging that the evidence was insufficient to support the disciplinary decision and that he therefore did not receive the required procedural protection of a decision supported by some evidence.

Benefield moved for summary judgment on several grounds. The court had already dismissed Moffett’s request for injunctive relief as time-barred, while allowing his damages claim to continue based on Moffett’s changed sentencing circumstances and his loss of good-time credits.

Court’s analysis

Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law. Benefield argued, among other things, that Moffett received due process, that Benefield did not adjudicate the disciplinary hearing, that the claim was barred by the Heck rule, and that qualified immunity applied.

The court agreed with the Heck argument and did not address the other grounds. The Heck rule generally prevents a person from obtaining damages through a civil-rights lawsuit when success would necessarily imply that a conviction, sentence, or other custody-related decision is invalid, unless that decision has already been reversed, set aside, or otherwise invalidated. The Supreme Court has applied this principle to prison disciplinary proceedings when the prisoner lost good-time credits.

The court relied on evidence that Moffett lost 360 days of good-time credits as a result of the disciplinary proceeding. It concluded that Moffett’s allegation—that there was no evidence supporting the disciplinary charge—would necessarily imply that the deprivation of those credits was invalid. The court also stated that Moffett had not shown that the disciplinary finding had been reversed or expunged, and that his credits had not been restored.

Disposition

The court held that Moffett’s damages claim was barred by the Heck rule. Because the request for injunctive relief had already been dismissed as time-barred and no request for relief remained, the court concluded that Benefield was entitled to summary judgment.

The court granted Benefield’s motion for summary judgment, directed the clerk to enter judgment, and ordered the case closed. Judge Edward M. Chen did not decide Benefield’s other arguments.