Gray v. White, 18 F.4th 463

Background

Timothy Gray, an inmate at Elayn Hunt Correctional Center, alleges officers Wells and White entered his cell, beat him, sprayed him with chemical agent in the shower, and that Sullivan and Slater continued beating him while he was restrained and dragged to a transport van, causing injuries (broken nose, bruised kidney).
Prison disciplinary reports describe Gray as intoxicated, noncompliant, resisting (kicking, spitting), breaking an officer’s radio, and list convictions for intoxication, defiance, aggravated disobedience, property destruction, and contraband.
The disciplinary board imposed multiple sanctions, including a cumulative forfeiture of 90 days’ good-time credit for several defiance/aggravated-disobedience violations; other sanctions were fines and privilege losses.
Gray administratively complained and received no relief, then sued under 42 U.S.C. § 1983 claiming excessive force (Fourth, Eighth, Fourteenth Amendments) and sought damages.
The district court granted summary judgment: it held some in-cell and in-shower excessive-force claims barred by Heck because they would conflict with disciplinary findings, and that post-shower beating claims were procedurally barred under the PLRA for failure to exhaust administrative remedies; Gray appealed.
The Fifth Circuit affirmed the PLRA dismissal, rejected Gray’s hearsay objection to use of disciplinary findings, but vacated the Heck ruling as premature and remanded for a fact-specific analysis of which claims, if any, necessarily imply invalidity of the disciplinary sanctions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck v. Humphrey bars Gray’s § 1983 excessive-force claims tied to disciplinary convictions that led to loss of good-time credits	Heck does not apply because excessive-force findings can coexist with rule violations; his claims do not necessarily negate disciplinary convictions	Heck bars claims that would necessarily imply invalidity of disciplinary convictions that affected sentence duration (loss of good time)	Vacated in part and remanded: court found record too fact-specific/incomplete to determine at summary judgment which claims are Heck-barred and directed further analysis on which disciplinary findings were necessary to the sanctions
Whether Gray exhausted administrative remedies under the PLRA for alleged post-shower/transport beatings	Gray’s administrative complaint and a jailhouse witness letter sufficiently put officials on notice of post-shower abuse	Gray’s administrative grievance did not describe the post-shower incidents with the detail required; he did not raise exhaustion in opposing summary judgment (waived)	Affirmed: post-shower claims were dismissed for failure to exhaust; the exhaustion argument was also waived by Gray for failing to respond to defendants’ summary-judgment exhaustion claim
Whether the district court erred by relying on disciplinary reports as inadmissible hearsay	Reports are hearsay and cannot be used to resolve summary judgment	Reports were used only to show the fact of a disciplinary finding, not to prove the truth of every factual allegation in the reports	Rejected Gray’s hearsay challenge: the reports were admissible for establishing that convictions occurred and the district court did not abuse discretion
Whether summary judgment was appropriate overall	Gray argued disputed factual issues precluded summary judgment on Eighth Amendment claims	Defendants argued Heck and PLRA required dismissal of the respective claims	Mixed result: PLRA dismissal affirmed; Heck analysis vacated and remanded for fact-specific determination; remainder of evidence to be considered on remand

Key Cases Cited

Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (§1983 claim barred if success would necessarily imply invalidity of conviction or sentence)
Hudson v. McMillian, 503 U.S. 1 (U.S. 1992) (Eighth Amendment excessive-force standard: malicious and sadistic vs. good-faith discipline)
Whitley v. Albers, 475 U.S. 312 (U.S. 1986) (force justified if applied in good-faith effort to maintain or restore discipline)
Muhammad v. Close, 540 U.S. 749 (U.S. 2004) (Heck extends to challenges that would affect duration of confinement)
Bourne v. Gunnels, 921 F.3d 484 (5th Cir. 2019) (discusses when disciplinary findings do not bar excessive-force claims under Heck)
Clarke v. Stalder, 154 F.3d 186 (5th Cir. 1998) (en banc) (prison disciplinary rulings that change sentence length count as convictions for Heck purposes)
Aucoin v. Cupil, 958 F.3d 379 (5th Cir. 2020) (distinguishes which excessive-force claims are Heck-barred based on where force occurred relative to disciplinary findings)
Ross v. Blake, 136 S. Ct. 1850 (U.S. 2016) (PLRA exhaustion requirement is mandatory)
Johnson v. Johnson, 385 F.3d 503 (5th Cir. 2004) (detail required in grievances to give officials a fair opportunity to address later lawsuit)
Ballard v. Burton, 444 F.3d 391 (5th Cir. 2006) (Heck bar applied only where claim success would negate an element of the conviction)
Bush v. Strain, 513 F.3d 492 (5th Cir. 2008) (Heck analysis is fact-intensive and analytical)