Marion Mosley v. Leamon White, 464 F. App'x 206

Mosley, an inmate at Coffield Unit, alleges White assaulted him by poking his face and left eye after forcing him to face the wall and place hands behind his back.
Injury included momentary blindness, facial abrasions, eye infection, swelling, and discoloration; medical treatment was delayed by inmate nurse’s refusal to treat pending accident/use-of-force report.
Mosley, proceeding in forma pauperis, filed §1983 complaint asserting Eighth Amendment excessive-force claim and seeking damages.
White moved for summary judgment asserting qualified immunity and dismissal under 42 U.S.C. §1997e(e); district court granted summary judgment.
Magistrate judge conducted Spears hearing; district court adopted report recommending dismissal of most claims, retaining the excessive-force claim; Mosley appealed.
Record included Mosley’s affidavits and inmate-witness affidavits; White’s corroborating reports and multiple sworn/unsworn documents; no medical record confirming injury corroborating severity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck/Edwards bar Mosley’s excessive-force claim.	Mosley argues Heck/Edwards do not bar the claim since it does not affect conviction or good-time credits.	White contends Heck/Edwards preclude damages for disciplinary harm.	Heck/Edwards do not bar the claim.
Whether Mosley’s Eighth Amendment claim is supported by the objective prong.	Injuries were non-minimal and constitutionally cognizable (eye injury).	Injuries were de minimis and not constitutionally cognizable.	Record shows injuries were not established as objectively cognizable; no durable injury shown.
Whether the evidence shows the use of force was excessive.	Force was applied unnecessarily and maliciously to cause harm.	Force used was not excessive given the circumstances and discipline context.	Insufficient evidence of objectively cognizable harm; no Eighth Amendment violation shown.
Whether Mosley’s evidence creates a material factual dispute preventing summary judgment.	Coercive affidavits and grievance records show injury and events.	Sworn records and lack of corroboration negate material dispute.	No genuine dispute of material fact; summary judgment appropriate.
Whether White is entitled to qualified immunity.	White violated clearly established rights by inflicting harm.	Conduct did not violate clearly established rights; reasonable officer would not know.	White entitled to qualified immunity.

Hudson v. McMillian, 503 U.S. 1 (1992) (core question: was force used in good-faith or sadistic manner; objective and subjective components; de minimis injury standard)
Siglar v. Hightower, 112 F.3d 191 (5th Cir. 1997) (de minimis injuries not cognizable under §1997e(e) unless more than de minimis)
Gomez v. Chandler, 163 F.3d 921 (5th Cir. 1999) (no categorical requirement that injuries be significant; fact-specific injury assessment)
Muhammad v. Close, 540 U.S. 749 (2004) ( Heck not implicated when no effect on underlying conviction or good-time credits)
Edwards v. Balisok, 520 U.S. 641 (1997) (procedural challenges in administrative processes; Heck framework applied)
Heck v. Humphrey, 512 U.S. 477 (1994) (ruin of conviction or good-time credits barred damages absent favorable ruling)
Eason v. Holt, 73 F.3d 600 (5th Cir. 1996) (requires more than de minimis injury to state Eighth Amendment claim)
Brown v. Callahan, 623 F.3d 249 (5th Cir. 2010) (burden-shifting in qualified-immunity analysis)