Charles M. McDaniel v. Troy Hershberger, Sickafoose, Wright, and Acevado

Summary

The United States District Court for the Northern District of Indiana dismissed Charles M. McDaniel’s prisoner civil-rights complaint under 28 U.S.C. § 1915A. The court held that his claims concerning disciplinary sanctions and loss of earned credit time could not proceed under 42 U.S.C. § 1983 because success would undermine the disciplinary finding, and that amendment would be futile.

Holdings

1. A prisoner cannot proceed under 42 U.S.C. § 1983 on claims challenging a disciplinary proceeding resulting in the loss of earned credit time until the disciplinary proceeding has been overturned, when success on the civil claims would undermine the disciplinary finding of guilt.
2. The complaint was subject to dismissal under 28 U.S.C. § 1915A because it failed to state a cognizable claim under § 1983.
3. Leave to amend was denied because amendment would be futile.

Questions Presented

1. Whether McDaniel could pursue under 42 U.S.C. § 1983 claims challenging disciplinary proceedings that resulted in the loss of earned credit time when success would undermine the disciplinary finding.
2. Whether the complaint should be dismissed under 28 U.S.C. § 1915A rather than amended.

Disposition

dismissed