Hamilton v. Lyons

Decision Date07 February 1996
Docket NumberNo. 95-10301,95-10301
Citation74 F.3d 99
PartiesSteven D. HAMILTON, Plaintiff-Appellant, v. D. LYONS, Lt. and DeSoto Police Department, Defendants-Appellees.
CourtU.S. Court of Appeals — Fifth Circuit

Steven D. Hamilton, Huntsville, TX, pro se.

Appeal from the United States District Court for the Northern District of Texas.

Before REYNALDO G. GARZA, BARKSDALE and EMILIO M. GARZA, Circuit Judges.

EMILIO M. GARZA, Circuit Judge:

Plaintiff Steven D. Hamilton appeals the district court's dismissal of his civil rights suit, brought pursuant to 42 U.S.C. Sec. 1983. The district court dismissed the suit as frivolous, pursuant to 28 U.S.C. Sec. 1915(d). We affirm.

I

Hamilton was arrested for multiple counts of aggravated sexual assault and indecency with a child. At the time of his arrest, Hamilton was on parole from prior convictions. Following his arrest, Hamilton was held at the DeSoto City Jail. Hamilton alleges that Defendant Lyons, an investigating officer in the DeSoto City Jail, told him that he would not be transferred to the Dallas County Jail until he made a statement regarding the charges pending against him. Hamilton also alleges that Lyons denied him visitation, telephone access, recreation, mail, legal materials, sheets, and showers. After Hamilton gave a statement regarding the charges pending against him, he was transferred to the Dallas County Jail. Prior to trial on the new charges, Hamilton's parole was revoked. Hamilton is currently serving a life sentence concurrently with multiple twenty-year sentences as an inmate of the Texas Department of Criminal Justice. Hamilton brought this Sec. 1983 civil rights suit challenging the actions of Lyons and the conditions of his confinement at the DeSoto City Jail. The district court dismissed his claims as frivolous. Hamilton timely filed his notice of appeal.

II

We review a district court's Sec. 1915(d) dismissal for abuse of discretion. Denton v. Hernandez, 504 U.S. 25, 33, 112 S.Ct. 1728, 1734, 118 L.Ed.2d 340 (1992). A complaint is "frivolous," for purposes of Sec. 1915(d), if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319, 325, 109 S.Ct. 1827, 1831-32, 104 L.Ed.2d 338 (1989). In Heck v. Humphrey, the Supreme Court held that a plaintiff who seeks to recover damages under Sec. 1983 for actions whose unlawfulness would render a conviction or sentence invalid must first prove that the conviction or sentence has been reversed, expunged, invalidated, or otherwise called into question. --- U.S. ----, ----, 114 S.Ct. 2364, 2372, 129 L.Ed.2d 383 (1994). A Sec. 1983 claim which falls under the rule in Heck is legally frivolous unless the conviction or sentence at issue has been reversed, expunged, invalidated, or otherwise called into question. Boyd v. Biggers, 31 F.3d 279, 283 (5th Cir.1994). A Sec. 1983 claim falls under the rule in Heck only when a judgment in favor of the plaintiff would necessarily imply the invalidity of a subsequent conviction or sentence. Therefore, we must first consider whether a judgment in favor of Hamilton on any of his claims would necessarily imply the invalidity of his convictions or sentences.

A

Hamilton alleges that Lyons violated his constitutional rights by using the conditions of Hamilton's confinement in the DeSoto City Jail in order to coerce him to give a statement. Statements obtained through either physical or psychological coercion of a defendant in police custody violate that defendant's Fifth Amendment privilege against self-incrimination, and thus cannot be used against him at trial. Miranda v. Arizona, 384 U.S. 436, 478-79, 86 S.Ct. 1602, 1630, 16 L.Ed.2d 694 (1966). If we were to find that Lyons coerced Hamilton to give a statement concerning the charges pending against him, that judgment would necessarily imply the invalidity of his subsequent convictions and sentences on those charges. See Harryman v. Estelle, 616 F.2d 870, 875 n. 12 (5th Cir.) (noting that prosecutorial use of involuntary statements can never be treated as harmless error), cert. denied, 449 U.S. 860, 101 S.Ct. 161, 66 L.Ed.2d 76 (1980). Thus, Heck bars this claim unless Hamilton proves that his convictions or sentences have been reversed, expunged, invalidated, or otherwise called into question. Since Hamilton has not made such a showing, this claim is legally frivolous. Accordingly, the district court did not err in dismissing the claim under Sec. 1915(d).

B

Hamilton also alleges that Lyons violated his constitutional rights by altering and destroying evidence relevant to the charges against him. Convictions tainted by the suppression, destruction, or alteration of material evidence violate a defendant's Fourteenth Amendment right to due process. Brady v. Maryland, 373 U.S. 83, 87, 83 S.Ct. 1194, 1196-97, 10 L.Ed.2d 215 (1963). If we were to find that Lyons altered and destroyed evidence relevant to the charges against Hamilton, that judgment would necessarily imply the invalidity of his subsequent convictions and sentences on those charges. See Heck, --- U.S. at ----, 114 S.Ct. at 2368, 2374 (holding that allegation of knowing destruction of exculpatory evidence necessarily implied invalidity of conviction and sentence). Thus, Heck also bars this claim unless Hamilton proves that his convictions or sentences have been reversed, expunged, invalidated, or otherwise called into question. Since Hamilton has not made such a showing, this claim is legally frivolous. Accordingly, the district court did not err in dismissing this claim under Sec. 1915(d).

C

Hamilton also alleges that the conditions at the DeSoto City Jail violated his constitutional rights. The Eighth Amendment prohibits the imposition of prison conditions that constitute "cruel and unusual punishment." Rhodes v. Chapman, 452 U.S. 337, 345, 101 S.Ct. 2392, 2398, 69 L.Ed.2d 59 (1981). The Fourteenth Amendment prohibits the imposition of conditions of confinement on pretrial detainees that constitute "punishment." Bell v. Wolfish, 441 U.S. 520, 535, 99 S.Ct. 1861, 1872, 60 L.Ed.2d 447 (1979). These allegations, challenging the conditions of Hamilton's confinement in and of themselves, are unrelated to the validity of Hamilton's subsequent convictions and sentences. Thus, a judgment finding the conditions at the DeSoto City Jail unconstitutional would not necessarily imply the invalidity of Hamilton's subsequent convictions and sentences. 1 Therefore, in order for this claim to be cognizable under Sec. 1983, Hamilton need not prove that his convictions or sentences have been reversed, expunged, invalidated, or otherwise called into question. We now address the merits of this claim.

The Eighth Amendment prohibits punishments which are cruel and unusual. Prison conditions constitute cruel and unusual punishment if they involve the "wanton and unnecessary infliction of pain [or if they are] grossly disproportionate to the severity of the crime warranting imprisonment." Rhodes, 452 U.S. at 347, 101 S.Ct. at 2399; see also Estelle v. Gamble, 429 U.S. 97, 103, 97 S.Ct. 285, 290, 50 L.Ed.2d 251 (1976) (holding deliberate indifference to an inmate's medical needs to be cruel and unusual); Hutto v. Finney, 437 U.S. 678, 687, 98 S.Ct. 2565, 2571, 57 L.Ed.2d 522 (1978) (finding prison conditions marked by insufficient diet, severe overcrowding, rampant violence, vandalism, and extended punitive isolation to be cruel and unusual). However, prison conditions are not unconstitutional simply because they are restrictive; restrictive conditions "are part of the penalty that criminal offenders pay for their offenses against society." Rhodes, 452 U.S. at 347, 101 S.Ct. at 2399.

In Bell v. Wolfish, 441 U.S. 520, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979), the Supreme Court evaluated the constitutionality of conditions of confinement of pretrial detainees. 2 Because they have not yet been convicted of the crime with which they are charged, pretrial detainees have a due process right not to be punished for that crime. Id. at 535 n. 16, 99 S.Ct. at 1872 n. 16. The Supreme Court has stated the distinction between conditions that may be constitutionally imposed on convicted prisoners and conditions that may be imposed on pretrial detainees as follows:

[T]he State does not acquire the power to punish with which the Eighth Amendment is concerned until after it has secured a formal adjudication of guilt in accordance with due process of law. Where the State seeks to impose punishment without such an adjudication, the pertinent constitutional guarantee is the Due Process Clause of the Fourteenth Amendment.

Ingraham v. Wright, 430 U.S. 651, 671-72 n. 40, 97 S.Ct. 1401, 1412-13 n. 40, 51 L.Ed.2d 711 (1977). Courts deciding the constitutionality of conditions of confinement of pretrial detainees must determine whether the conditions complained of are imposed for the purpose of punishment. Bell, 441 U.S. at 538, 99 S.Ct. at 1873. Courts may find a punitive purpose upon direct proof of an expressed intent by detention facility officers to punish the pretrial detainee for the crime with which the detainee has been charged but not yet convicted. Id. at 538, 99 S.Ct. at 1873-74. In addition, courts may infer a punitive purpose if the challenged condition or restriction is not reasonably related to a legitimate governmental objective. 3 Id. at 539, 99 S.Ct. at 1874.

Hamilton challenges the conditions of his confinement at the DeSoto City Jail. We must first determine whether the standard announced in Bell should be extended to the claims of a parolee challenging conditions of confinement during his detention following an arrest for a crime committed while on parole. This issue has not been decided by this circuit or any other circuit. 4 In some respects, a detained parolee is like the pretrial detainee envisioned by the Supreme Court in Bell. The State does not acquire the power to punish a person for the commission of a particular crime until after the defendant is found...

To continue reading

Request your trial
494 cases
  • Akins v. Liberty Cnty.
    • United States
    • U.S. District Court — Eastern District of Texas
    • January 9, 2014
    ...688 F.2d 266 (5th Cir. 1982)). The Constitution, however, is not concerned with "a de minimis level of imposition." Hamilton v. Lyons, 74 F.3d 99, 106 (5th Cir. 1996). Further, "[t]o succeed on a claim under Section 1983 for lack of exercise, a prisoner must establish 'the existence of any ......
  • Diaz v. Tocci, CIVIL NO. SA-16-CA-356-DAE (PMA)
    • United States
    • U.S. District Court — Western District of Texas
    • June 16, 2016
    ...and that claims for monetary damages were foreclosed by Heck); Hudson v. Hughes, 98 F.3d 868, 872-73 (5th Cir. 1996); Hamilton v. Lyons, 74 F.3d 99, 102-03 (5th Cir. 1996) (applying the rule in Heck to collateral attacks upon a criminal conviction and parole revocation arising from an alleg......
  • Humphries v. Various Federal USINS Employees
    • United States
    • U.S. Court of Appeals — Fifth Circuit
    • January 21, 1999
    ...conceded as much at oral argument, at least with respect to Humphries' claims for mistreatment while in detention. 12 Cf. Hamilton v. Lyons, 74 F.3d 99 (5th Cir.1996) (holding that Heck does not render a prisoner's claim challenging the conditions of his confinement uncognizable under § We ......
  • McMillian v. Johnson
    • United States
    • U.S. Court of Appeals — Eleventh Circuit
    • July 9, 1996
    ...suffices to show unconstitutional pretrial punishment. Bell, 441 U.S. at 538 & n. 20, 99 S.Ct. at 1873-74 & n. 20; Hamilton v. Lyons, 74 F.3d 99, 104 (5th Cir.1996) (stating that expressed intent by officers to punish pretrial detainee shows unconstitutional pretrial punishment); Hause v. V......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT