Garrick Lashun Miller v. Brad Taylor, et al.

Summary

The United States District Court for the Northern District of Mississippi dismissed with prejudice a pro se prisoner’s 42 U.S.C. § 1983 action and his motion seeking immediate release. The court concluded that the plaintiff’s arrest, detention, and post-release-supervision revocation were supported by state-court records, and that claims challenging the revocation and confinement were barred under Heck v. Humphrey. The court dismissed the property-deprivation claim without prejudice under the Parratt/Hudson doctrine and rejected the plaintiff’s supervisory-liability allegations.

Holdings

1. A random and unauthorized deprivation of a prisoner's property by a state actor does not support a federal due-process claim when the state provides an adequate post-deprivation remedy. Mississippi law provided Miller an adequate remedy for the alleged taking, so the federal property claim could not proceed under the Parratt/Hudson doctrine.
2. A § 1983 claim for damages, declaratory relief, or injunctive relief is not cognizable when success would necessarily imply the invalidity of an outstanding conviction, sentence, parole or post-release-supervision revocation, or resulting confinement, unless that judgment or revocation has already been invalidated. Miller's claims and request for immediate release were therefore barred by Heck v. Humphrey.
3. Miller failed to state claims based on allegedly unlawful arrest or detention because the record showed that the search was conducted pursuant to a warrant supported by probable cause, he was on post-release supervision when arrested, and his detention arose from a valid revocation process rather than detention without charges.
4. A supervisory official cannot be held liable under § 1983 solely because of the official's supervisory role, participation in the grievance process, or failure to supervise. Liability requires personal participation in the constitutional violation or implementation of an unconstitutional policy that caused the injury.

Questions Presented

1. Whether Miller stated a federal due-process claim for the seizure and forfeiture of his money when Mississippi provided an adequate post-deprivation remedy.
2. Whether Miller's challenges to his post-release-supervision revocation, resulting confinement, arrest, and detention were cognizable under § 1983 or were barred by Heck v. Humphrey.
3. Whether Miller stated claims for false imprisonment, cruel and unusual punishment, conspiracy, or failure to prevent a conspiracy based on his allegedly unlawful imprisonment.
4. Whether unidentified supervisory defendants could be held liable under § 1983 based solely on their supervisory roles or alleged failure to prevent the challenged conduct.
5. Whether Miller was entitled to immediate release through temporary restraining or prospective and declaratory relief.

Disposition

dismissed