Biggers v. Walls, 1:17-cv-00101

Kevin Randell Biggers, an Arkansas inmate, filed a pro se § 1983 suit challenging county jail disciplinary proceedings and a resulting parole revocation and transfer to the Arkansas Department of Correction (ADC).
After an August 29, 2017 parole-violation hearing, Biggers was ordered to remain in county jail for 90 days contingent on behavior; subsequent jail discipline altered that outcome.
On September 1 and September 6, 2017, Biggers received disciplinary sanctions (72-hour lockdowns) for minor infractions; the second disciplinary produced a full parole revocation and transfer to the ADC.
Biggers alleges selective enforcement (other inmates not disciplined), an inadequate grievance procedure, and that the transfer/revocation was retaliatory for filing a grievance.
The magistrate judge screened the amended complaint under 28 U.S.C. §§ 1915A, 1915(e)(2) and found the factual allegations insufficient to state viable § 1983 claims, recommending dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due process re: lockdowns/parole revocation	Biggers contends disciplinary lockdowns and revocation deprived him of liberty without due process	Defendants rely on ordinary disciplinary procedures and lack of a protected liberty interest in short lockdowns	Dismissed: 72-hour lockdowns not an "atypical and significant" hardship; no protected liberty interest shown for due process claim
Retaliation for filing grievance (transfer to ADC)	Biggers asserts he was transferred/extended because he filed a grievance after the disciplinary	Defendants assert transfer resulted from valid disciplinary/parole-revocation process	Court construed claim liberally as alleging retaliation but barred by Heck because success would invalidate the parole revocation
Equal protection (selective enforcement)	Biggers claims other inmates committed same acts without punishment	Defendants implicitly deny a constitutional violation, noting no protected class or identical comparators	Dismissed: allegations too conclusory; no protected class or adequate comparator alleged
Challenge to grievance procedure	Biggers claims the jail’s grievance system is inadequate	Defendants note inmates have no constitutional right to a grievance procedure	Dismissed: grievance-process complaints not actionable under § 1983

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must plead plausible claim, not mere labels and conclusions)
Sandin v. Conner, 515 U.S. 472 (1995) (liberty interests protected under Due Process depend on whether conditions impose atypical and significant hardship)
Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claim that would invalidate a conviction or sentence is barred until conviction/sentence invalidated)
Spencer v. Kemna, 523 U.S. 1 (1998) (Heck principles apply in parole-revocation context)
Phillips v. Norris, 320 F.3d 844 (8th Cir. 2003) (prisoner must show deprivation of life, liberty, or property to state due process claim)
Portley-El v. Brill, 288 F.3d 1063 (8th Cir. 2002) (administrative and disciplinary segregation usually not atypical and significant)
Goff v. Burton, 91 F.3d 1188 (8th Cir. 1996) (transfer in retaliation for exercising constitutional rights states a claim)
Flick v. Alba, 932 F.2d 728 (8th Cir. 1991) (no constitutional right to prison grievance procedures)