Wayne LaFountain v. Shirlee Harry, 716 F.3d 944

LaFountain, a Michigan prisoner, sued prison officials for retaliatory actions tied to grievances and lawsuits.
He alleges transfer from Lakeland to Muskegon, aided by a settlement, exposed him to farther from family and prior retaliation.
He alleges damages to his typewriter caused by third-shift officers under Cooley’s supervision.
He alleges he was placed in a cell with a mentally ill prisoner, Riley, leading to threats and extended segregation.
He alleges retaliatory acts culminated in loss of 770 days of good-time credits following misconduct findings.
The district court dismissed the complaint with prejudice under PLRA screening; the court later denied leave to amend, and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether any defendant’s action was an adverse action for retaliation	LaFountain alleges transfers, typewriter damage, and cell assignment were adverse	Transfer generally not adverse; typewriter damage requires causation; cell assignment routine	Yes for transfer, typewriter damage via Cooley, and cell with Riley (with conditions for others)
Whether Heck v. Humphrey bars the retaliation claim based on misconduct charges	Loss of good-time credits tied to misconduct violated by defendants	Heck bars actions that would invalidate confinement; claimed entrapment not allowed	Bar applies; claims based on misconduct hearings barred
Whether equal-protection claim is viable	Bradley treated differently without knowledge of misconduct	Bradley’s conduct not shown to be known or charged by defendants	Equal-protection claim failed
Whether district court erred by dismissing without leave to amend under PLRA	McGore should be overruled; amendment allowed under Rule 15(a)	McGore controls; no amendment allowed	McGore overruled; district court may allow amendment; remanded for amendment considerations

Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (retaliation standard for adverse action and causation in prison contexts)
Wilkinson v. Dotson, 544 U.S. 74 (U.S. 2005) (retains universal rule that prisoners cannot seeks relief that would affect sentence length without invalidating conviction)
Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (bar on §1983 damages when success would imply invalidity of conviction or sentence)
Edwards v. Balisok, 520 U.S. 641 (U.S. 1997) (procedural challenges to disciplinary proceedings barred when affecting confinement duration)
Jones v. Bock, 549 U.S. 199 (U.S. 2007) (PLRA screening does not override ordinary procedural requirements; allow amendment under Rule 15(a))