Jones v. TDCJ Pardon and Parole Division
1:23-cv-00459
E.D. Tex.Apr 26, 2024Background
- Wayne Jones, an inmate at Jefferson County Correctional Facility, filed a pro se civil rights complaint under 42 U.S.C. § 1983.
- Jones sued the Texas Department of Criminal Justice's Pardons and Paroles Division and parole officer Shedrick Lewis.
- He alleges he was arrested on August 2, 2023, for a parole violation and not released after the statutory time frame expired on November 2, 2023, as required by Texas Government Code § 508.282.
- Jones claims he remains confined because the parole revocation warrant was not withdrawn despite the expiration of the statutory period.
- He seeks monetary damages for what he argues is wrongful continued confinement.
- The matter was referred to a Magistrate Judge for a Report and Recommendation on whether the complaint states a valid claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to monetary damages for wrongful confinement | He was not released as legally required | Not stated; analysis based on precedent | Barred by Heck v. Humphrey; must show confinement was invalidated |
| Sufficiency of complaint under § 1915A (frivolity) | Claims officials violated law and rights | Not stated | Dismissed for failure to state claim per Heck and § 1915A |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (bars § 1983 damages claims challenging validity of confinement unless conviction has been invalidated)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (articulates the "plausibility" standard for pleading a claim in federal court)