Clark v. Dept of Public Safety, 141 F.4th 653

Torriana Clark, an inmate at Rayburn Correctional Center (RCC), sued prison officials under 42 U.S.C. § 1983, alleging that Lieutenant Lance Wallace used excessive force in violation of his constitutional rights.
According to Clark, while seeking medical help for illness, multiple officers used physical force; Wallace allegedly twisted his ankle, choked him, and knocked him unconscious.
Prison officials provided a conflicting account, describing Clark as combative and resisting orders, which led to their use of force to restrain him.
Following the incident, Clark was found guilty of disciplinary infractions and lost good-time credits as a result, some based on reports that described his resistance.
The district court granted partial summary judgment for the defendants, finding Clark's § 1983 claim barred by Heck v. Humphrey because success on his claim would invalidate the disciplinary conviction.
Clark appealed, challenging both the summary judgment and the denial of leave to amend his complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Heck v. Humphrey bar Clark’s § 1983 claim?	Clark argued the events cited for excessive force were distinct from those underlying his disciplinary convictions.	Defendants argued that Clark's § 1983 claim challenges the same facts as those for which he lost good-time credit.	Heck bars the claim; affirm summary judgment.
Should Clark be granted leave to amend his complaint?	Clark argued amendment would allow him to reconcile his claims with the video evidence and possibly avoid the Heck bar.	Defendants claimed amendment would be futile, as underlying facts would still contradict guilty pleas.	Denial affirmed; amendment would be futile.
Was denial of a qualified immunity briefing schedule proper?	Clark argued the court should have set a schedule to address qualified immunity.	Defendants argued it was premature or unnecessary once Heck applied.	Moot due to ruling on main issues.

Heck v. Humphrey, 512 U.S. 477 (1994) (bars § 1983 claims that would imply invalidity of a conviction or sentence until conviction is set aside)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard; burden-shifting framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for identifying genuine issue of material fact)
Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment excessive force standard for prison officials)
Wallace v. Kato, 549 U.S. 384 (2007) (limits on § 1983 claims in face of unresolved criminal proceedings)