Toran Peterson v. Richard Johnson, 714 F.3d 905

Peterson, a prisoner at Ionia Correctional Facility, sued Officers Johnson and Lindy under 42 U.S.C. § 1983 alleging excessive force in violation of the Eighth Amendment.
The sole disputed fact was whether Johnson or Peterson grabbed the other's hand as the cell door closed during a Tension-filled incident, leading to a two-minute struggle and Peterson’s subsequent 30-day detention for assault and battery at a major misconduct hearing.
The hearing officer found that Peterson grabbed Johnson’s hand and pulled it into the cell, and he issued a final decision upholding the assault-and-battery conviction; Peterson did not pursue state judicial review of that decision.
Peterson later sued in federal court; defendants moved for summary judgment arguing the hearing officer’s finding precluded Peterson’s Eighth Amendment claim.
The district court granted summary judgment on all claims except the Eighth Amendment claim, and the Sixth Circuit affirmed, applying a preclusion analysis under Elliott and Michigan law.
The majority held that the hearing officer’s factual finding was rendered in a judicial capacity, properly adjudicated, and entitled to preclusive effect in Peterson’s collateral § 1983 action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the hearing officer’s factfinding is preclusive in § 1983 action	Peterson contends the factfinding is binding only if validly final and fully litigated, but not dispositive of all constitutional claims.	Johnson and Lindy argue the hearing officer’s finding resolves the essential factual issue and should bar the § 1983 claim.	Yes; the finding is preclusive on the disputed factual issue in the collateral action.
Whether Peterson had a full and fair opportunity to litigate the factual dispute	Peterson asserts he had a meaningful opportunity to contest and present evidence, including witnesses, without counsel.	Defendants contend the process resembled a judicial hearing with procedural protections, so Peterson had a full and fair opportunity to litigate.	Yes; Michigan’s major misconduct hearing provided a full and fair opportunity to litigate the factual dispute.
Michigan and Elliott-based criteria for agency preclusion apply	Preclusion should not apply because the Eighth Amendment claim is distinct from the state agency’s assault-and-battery ruling.	Elliott’s framework supports preclusion where the agency acted in a judicial capacity, the issue was litigated, and review was available.	Preclusion applies to the agency’s factual finding under Elliott and Michigan state-law standards.

University of Tennessee v. Elliott, 478 U.S. 788 (U.S. 1986) (establishes four criteria for giving preclusive effect to a state agency’s factual determinations in § 1983 actions)
Lockett v. Suardini, 526 F.3d 866 (6th Cir. 2008) (facts and legal questions may co-exist; state findings may preclude some claims but not others)
Hudson v. McMillian, 503 U.S. 1 (U.S. 1992) (defines objective and subjective components of excessive force in Eighth Amendment analysis)
Wilkins v. Gaddy, 559 U.S. 34 (U.S. 2010) (excessive-force standard focuses on the nature of force rather than injury extent)
Williams v. Curtin, 631 F.3d 380 (6th Cir. 2011) (post- Elliott framework regarding preclusion and adjudicatory findings in prison proceedings)
McCormick v. Braverman, 451 F.3d 382 (6th Cir. 2006) (outline of the first-stage preclusion analysis for § 1983 cases)
Monat v. State Farm Ins. Co., 469 Mich. 679 (Mich. 2004) (thirteen-factor framework for assessing full and fair opportunity to litigate in Michigan)
Nummer v. Treasury Dep’t, 533 N.W.2d 250 (Mich. 1995) (two-stage test for agency adjudication preclusion in Michigan)
Shelly v. Johnson, 849 F.2d 228 (6th Cir. 1988) (prison misconduct findings not generally revisited in federal court)
Gee v. Dep’t of Corr., None (Mich. App. 1999) (agency adjudicatory nature of major misconduct hearings)