Randy Jackson v. John Hochberg, 669 F. App'x 274

Plaintiff Randy Dale Jackson, a Mississippi prisoner, sued under 42 U.S.C. § 1983 alleging excessive force and denial of medical care after being forced face-down and tightly handcuffed during a prison gym riot.
The incident occurred amid gang unrest in the gym; at least one inmate was stabbed and officers used riot guns and chemical agents to restore order.
Jackson alleged abrasions, bruises, and pain from the tight handcuffs and claimed medical staff denied treatment.
The district court dismissed the complaint as frivolous for failure to state Eighth Amendment claims; Jackson appealed.
The Fifth Circuit reviewed de novo and considered whether the facts, taken as true, could support claims of excessive force, deliberate indifference to medical needs, or judicial bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force	Jackson: handcuffing face-down on dirty floor and overly tight cuffs inflicted harm and was excessive.	Officers: force was used to restore order amid a violent riot and was not malicious.	Dismissed — force was applied in good-faith to restore discipline, not maliciously.
Denial of medical care	Jackson: medical staff refused treatment for abrasions and bruises from handcuffs.	Prison: injuries were minor and did not amount to serious medical need.	Dismissed — injuries were minor, no serious medical need or lasting harm shown.
Judicial bias	Jackson: magistrate ignored facts and law, showing bias.	Court: adverse rulings alone don’t establish bias; record lacks support for bias.	Dismissed — no evidence of bias.
Sanctions / in forma pauperis strikes (28 U.S.C. § 1915(g))	Jackson: appealed the dismissals.	Court: prior frivolous filings count as strikes; repeated frivolous appeals warrant sanctions.	Appeal dismissed as frivolous; Jackson accrues third strike and is barred from IFP absent imminent danger; warned about future sanctions.

Geiger v. Jowers, 404 F.3d 371 (5th Cir.) (standard of de novo review for § 1915 dismissals)
Brewster v. Dretke, 587 F.3d 764 (5th Cir.) (definition of frivolous)
Samford v. Dretke, 562 F.3d 674 (5th Cir.) (12(b)(6) standard applied to § 1915 dismissals)
Harris v. Hegmann, 198 F.3d 153 (5th Cir.) (pleading standard for dismissal)
Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment excessive force test)
Farmer v. Brennan, 511 U.S. 825 (1994) (standard for deliberate indifference to inmate safety)
Wilson v. Seiter, 501 U.S. 294 (1991) (serious medical need requirement)
Liteky v. United States, 510 U.S. 540 (1994) (adverse rulings alone insufficient to show judicial bias)
Howard v. King, 707 F.2d 215 (5th Cir.) (frivolous appeal authority)
Adepegba v. Hammons, 103 F.3d 383 (5th Cir.) (strikes under § 1915(g))
Coughlan v. Starkey, 852 F.2d 806 (5th Cir.) (sanctions for abusive filings)