James Brown v. Vasquez, 699 F. App'x 335

James A. Brown, a Texas prisoner, sued under 42 U.S.C. § 1983 alleging excessive force, retaliation, unlawful disciplinary proceedings, property deprivation, and related constitutional violations arising from two cell extractions.
Defendants named: Sgt. Vasquez and C.O. R. Hughes. Brown consented to proceed before a magistrate judge.
Magistrate judge dismissed the complaint as frivolous and for failure to state a claim under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b)(1); Brown appealed.
Court applied de novo review and construed facts in Brown’s favor but found force used during extraction was a good-faith effort to restore discipline due to Brown’s noncompliance and resistance.
The court held Brown’s challenges to his prison disciplinary finding and forfeited good-time credits barred by Heck/Edwards because he had not shown the disciplinary decision was overturned.
The court rejected retaliation and property-deprivation claims for lack of plausible retaliatory motive and because Texas provides adequate post-deprivation remedies (Parratt/Hudson); denied leave to amend as Brown had already been allowed to clarify claims and had alleged his best case. Court affirmed dismissal and imposed a § 1915(g) strike bar; warned against frivolous filings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force (Eighth Amendment)	Force used during extractions was excessive.	Force was a good-faith effort to maintain/restore discipline given Brown’s refusal to comply and resistance.	Dismissed: force was reasonable under Hudson; no viable Eighth Amendment claim.
Validity of disciplinary proceeding / recovery of good-time credits	Disciplinary finding and forfeiture invalid; seeks damages/credits.	Heck/Edwards bar § 1983 claims that would imply invalidity of an un-reversed disciplinary finding.	Dismissed: claim barred by Heck and Edwards until disciplinary finding overturned.
Retaliation	Defendants conducted campaign of harassment (meal denial, chemical spray, strip searches, false crisis management, property loss).	No direct evidence or chronology to plausibly infer retaliatory motive.	Dismissed: pleadings fail to plausibly allege retaliation.
Property deprivation / procedural due process	Property was taken; alleges due-process violation.	Parratt/Hudson: random, unauthorized deprivation does not give rise to § 1983 if adequate state post-deprivation remedies exist.	Dismissed: Texas provides adequate post-deprivation remedies (conversion/tort), so no § 1983 due-process claim.

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal-standard for plausibility and pleading failure-to-state claims)
Geiger v. Jowers, 404 F.3d 371 (5th Cir. 2005) (de novo review of § 1915 dismissals)
Hudson v. McMillian, 503 U.S. 1 (1992) (excessive-force inquiry: good-faith effort to maintain/restore discipline vs. malicious infliction)
Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 barred if judgment would imply invalidity of conviction or sentence)
Edwards v. Balisok, 520 U.S. 641 (1997) (Heck rule applies to prison disciplinary proceedings affecting good-time credits)
Clarke v. Stalder, 154 F.3d 186 (5th Cir. 1998) (prisoner cannot recover forfeited good-time credits in § 1983 action)
Allen v. Thomas, 388 F.3d 147 (5th Cir. 2004) (Parratt/Hudson post-deprivation remedy framework)
Murphy v. Collins, 26 F.3d 541 (5th Cir. 1994) (Texas tort remedies afford adequate post-deprivation process)
Bazrowx v. Scott, 136 F.3d 1053 (5th Cir. 1998) (denial of leave to amend where plaintiffs already alleged their best case)