Byrd, Phillip v. Buesgen, Chris, 3:23-cv-00064

Plaintiff Phillip Byrd, a prisoner at Stanley Correctional Institution, alleges that staff blocked his access to the courts, confiscated his legal materials, and retaliated against him for grievances.
Byrd’s claims include constitutional and state-law claims against Warden Buesgen and Education Director Van Ert.
Defendants previously succeeded on an exhaustion-based partial summary judgment, and now moved for partial judgment on the pleadings.
The court considered whether Byrd's access-to-court claims were barred under Heck v. Humphrey, and addressed related negligence and retaliation claims.
Byrd sought additional discovery and delayed summary judgment briefing, which the court ultimately denied.
The court partially granted defendants’ motion, striking the trial date and requiring new briefing on the remaining claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of motion for judgment on the pleadings	Defendants’ motion is untimely	Motion is timely under Rule 12(c)	Motion was timely
Access-to-courts claim (Buesgen)	Prevented from filing meritorious postconviction motions	Claim barred by Heck unless conviction revoked	Dismissed without prejudice (barred by Heck)
Retaliation claims (Van Ert)—legal materials	Van Ert retaliated by confiscating/tampering with USB/legal work	Action does not necessarily imply invalidation	Motion denied; claim may proceed
Application of Heck to state negligence claims	State-law claims not barred by Heck	Heck bars all related claims	Heck does not bar state negligence claims

Heck v. Humphrey, 512 U.S. 477 (1994) (bars § 1983 damages claims that would necessarily imply invalidity of a conviction unless the conviction is overturned)
Hoard v. Reddy, 175 F.3d 531 (7th Cir. 1999) (plaintiff must show legally cognizable harm in access-to-courts claims)
Burd v. Sessler, 702 F.3d 429 (7th Cir. 2012) (access-to-courts claim barred by Heck absent vacatur of conviction)