Kirk Dixon v. Nathan S. Pollock, 887 F.3d 1235

In August 2013 at Everglades CI, Officer Nathan Pollock and other officers encountered prisoner Kirk Dixon after Dixon complained about a handicapped inmate assigned to a top bunk.
Dixon alleges Pollock aggressively confronted him, stepped on his heel, slammed him to the floor, and kicked him for ~2 minutes, causing serious injuries.
Pollock’s account: Dixon ignored orders, made a fist, lunged, and Pollock used force to subdue him; medical evidence of trauma is disputed.
Dixon was disciplined for Battery or Attempted Battery on a Correctional Officer and lost gain-time credits.
Dixon filed a § 1983 excessive-force suit; the district court dismissed it for lack of subject-matter jurisdiction under Heck v. Humphrey.
The Eleventh Circuit vacated and remanded, holding Heck did not bar the § 1983 claim because success on the claim would not necessarily imply invalidity of the disciplinary sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck/Balisok bars Dixon’s § 1983 excessive-force suit because he lost gain time in a disciplinary proceeding	Dixon contends his § 1983 claim for excessive force can succeed without invalidating the disciplinary loss of gain time	Pollock argues Dixon’s complaint alleges facts (no lunge) that contradict the factual basis for the disciplinary conviction, so Heck bars the suit	Court held Heck does not bar the suit because success on the § 1983 claim is not a logical necessity that would invalidate the disciplinary result
Whether an allegation that contradicts facts underlying a conviction automatically triggers Heck (the inconsistent-factual-allegations gloss)	Dixon argues his allegations need not be read as necessarily negating the discipline; permissive inferences allow coexistence	Pollock relies on the inconsistent-factual rule (from McCann/Okoro) to assert Heck applies here	Court limited the inconsistent-factual-allegation rule to narrow cases where the contradictory factual allegation is essential to the § 1983 claim; it is not met here

Heck v. Humphrey, 512 U.S. 477 (Heck doctrine bars § 1983 claims that would necessarily imply invalidity of conviction or sentence)
Edwards v. Balisok, 520 U.S. 641 (Heck extended to prison disciplinary proceedings that affect good-time credits)
Dyer v. Lee, 488 F.3d 876 (11th Cir. 2007) (Heck bars only where judgment for plaintiff would be a logical necessity to negate punishment)
McCann v. Neilsen, 466 F.3d 619 (7th Cir. 2006) (discusses inconsistent-factual-allegations rule; reversal where complaint reasonably construed did not necessarily negate conviction)
Okoro v. Callaghan, 324 F.3d 488 (7th Cir. 2003) (example where § 1983 allegations directly contradicted facts underlying criminal conviction)
Willingham v. Loughnan, 261 F.3d 1178 (11th Cir. 2001) (recognizes excessive-force action and battery conviction may coexist)