James Edward Probst v. Arturo Beckett

CourtDistrict Court, N.D. Texas
DecidedMarch 26, 2026
Docket2:24-cv-00014
StatusUnknown

This text of James Edward Probst v. Arturo Beckett (James Edward Probst v. Arturo Beckett) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Edward Probst v. Arturo Beckett, (N.D. Tex. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS AMARILLO DIVISION JAMES EDWARD PROBST, § TDCJ-CID No. 01699988, § § Plaintiff, § § v. § 2:24-CV-14-Z-BR § ARTURO BECKETT, § § Defendant. § FINDINGS, CONCLUSIONS AND RECOMMENDATION TO GRANT DEFENDANT’S MOTION FOR SUMMARY JUDGMENT and DENY PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT Before the Court is a Motion for Summary Judgment filed by Defendant Arturo Beckett (“Beckett”) (ECF 51) and a Motion for Summary Judgment filed by Plaintiff James Edward Probst (“Probst”) (ECF 47). For the reasons stated herein, the Magistrate Judge recommends that Beckett’s Motion be GRANTED and Probst’s Motion be DENIED as moot. I. BACKGROUND Probst, a prisoner in the Texas Department of Criminal Justice, alleges that Beckett used excessive force on him while Probst was housed in the Clements Unit. Specifically, he claims that, while Probst was handcuffed, Beckett ran him into a wall, “slammed” him in the head and, once Probst was on the ground, used his arm to choke Probst into unconsciousness. (ECF 3 at 4, 6; ECF 11 at 9). He filed this lawsuit against Beckett on January 23, 2024, and subsequently moved for summary judgment. (ECF 47). Beckett also filed a summary judgment motion, alleging that Probst failed to exhaust his administrative remedies before filing suit. (ECF 51). Probst responded to the motion on January 30, 2026, disputing Beckett’s claim. (ECF 53). II. SUMMARY JUDGMENT STANDARD The purpose of summary judgment is to isolate and dispose of factually unsupported claims or defenses. See Celotex Corp. v. Catrett, 477 U.S. 317, 327 (1986). Summary judgment is proper

if the pleadings, the discovery and disclosure materials on file, and any affidavits show that “there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). A dispute about a material fact is genuine “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The Court must resolve all reasonable doubts in favor of the party opposing the motion. Casey Enters., Inc. v. Am. Hardware Mut. Ins. Co., 655 F.2d 598, 602 (5th Cir. 1981). The movant has the burden to show that there is no genuine issue of material fact and that it is entitled to judgment as a matter of law. Anderson, 477 U.S. at 247. If the movant bears the

burden of proof on a claim or defense on which it is moving for summary judgment, it must come forward with evidence that establishes “beyond peradventure all of the essential elements of the claim or defense.” Fontenot v. Upjohn Co., 780 F.2d 1190, 1194 (5th Cir. 1986). The nonmovant then must provide affirmative evidence to defeat summary judgment. Anderson, 477 U.S. at 257. No “mere denial of material facts nor...unsworn allegations [nor] arguments and assertions in briefs or legal memoranda” will suffice to carry this burden. Moayedi v. Compaq Comput. Corp., 98 F. App’x 335, 338 (5th Cir. 2004). The Court requires “significant probative evidence” from the nonmovant in order to dismiss a request for summary judgment supported appropriately by the movant. United States v. Lawrence, 276 F.3d 193, 197 (5th Cir. 2001). The Court must consider all evidence but must not make any credibility determinations or weigh the evidence. Turner v.

Baylor Richardson Med. Ctr., 476 F.3d 337, 343 (5th Cir. 2007). Because he proceeds pro se, Probst’s pleadings are held to a less stringent standard than those drafted by attorneys. See Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam); see also Erickson v. Pardus, 551 U.S. 89, 94 (2007) (“A document filed pro se is to be liberally construed”) (quotation omitted). Nevertheless, pro se parties must “still comply with the rules of procedure and make arguments capable of withstanding summary judgment.” Ogbodiegwu v. Wackenhut

Corr. Corp., 202 F.3d 265, 1999 WL 1131884, at *2 (5th Cir. Nov. 10, 1999); Yazdchi v. Am. Honda Fin. Corp., 217 F. App’x 299, 304 (5th Cir. 2007) (“The right of self-representation does not exempt a party from compliance with relevant rules of procedural and substantive law.”) (citing Hulsey v. Texas, 929 F.2d 168, 171 (5th Cir. 1991)). III. LEGAL ANALYSIS A. The Prison Litigation Reform Act (“PLRA”) Exhaustion Requirement. Beckett moves for summary judgment based on his affirmative defense that Probst has not

exhausted his administrative remedies. The Prison Litigation Reform Act (“PLRA”) provides that “[n]o action shall be brought with respect to prison conditions under section 1983 of this title, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). “[T]he PLRA’s exhaustion requirement applies to all inmate suits about prison life, whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong.” Porter v. Nussle, 534 U.S. 516, 532 (2002) (citation omitted). The U.S. Supreme Court has described the PLRA exhaustion provision as a “mandatory exhaustion” statute and has “reject[ed] every attempt to deviate . . . from its textual mandate.” Ross v. Blake, 578 U.S. 632, 639-40 (2016); see also Jones v. Bock, 549 U.S. 199, 211 (2007) (“There

is no question that exhaustion is mandatory under the PLRA and that unexhausted claims cannot be brought in court”) (citing Porter, 534 U.S. at 524). The only “textual exception to mandatory exhaustion” in the PLRA is if administrative remedies are unavailable. Ross, 578 U.S. at 642. Administrative relief is available so long as the prison administrator has the “authority to take some action in response to a complaint,” even if that relief does not provide the precise “remedial action an inmate demands to the exclusion of all other forms of redress.” Booth v. Churner, 532

U.S. 731, 736 and n.6 (2001) (“An inmate must exhaust irrespective of the forms of relief sought and offered through administrative avenues.”). As a result, “a court may not excuse a failure to exhaust, even to take [special] circumstances into account.” Ross, 578 U.S. at 639. The Fifth Circuit takes a strict approach to the exhaustion requirement. Wilson v. Epps, 776 F.3d 296, 299-300 (5th Cir. 2015) (“[P]risoners must not just substantially comply with the prison’s grievance procedures, but instead must exhaust available remedies properly” (internal quotation omitted)). The Fifth Circuit also has recognized that “[w]hen a defendant asserts the defense of lack of exhaustion, the district court should rule on [the exhaustion] issue before allowing the case to proceed to the merits.” Nottingham v. Finsterwald, 582 F. App’x 297, 297-98

(5th Cir. 2014) (citing Dillon v.

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Related

United States v. Lawrence
276 F.3d 193 (Fifth Circuit, 2001)
Moayedi v. Compaq Computer Corp.
98 F. App'x 335 (Fifth Circuit, 2004)
Turner v. Baylor Richardson Medical Center
476 F.3d 337 (Fifth Circuit, 2007)
Yazdchi v. American Honda Finance Corp.
217 F. App'x 299 (Fifth Circuit, 2007)
Dillon v. Rogers
596 F.3d 260 (Fifth Circuit, 2010)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Booth v. Churner
532 U.S. 731 (Supreme Court, 2001)
Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Marian Fontenot, Etc. v. The Upjohn Company
780 F.2d 1190 (Fifth Circuit, 1986)
James Skip Hulsey v. State of Texas
929 F.2d 168 (Fifth Circuit, 1991)
ACS RECOVERY SERVICES, INC. v. Griffin
676 F.3d 512 (Fifth Circuit, 2012)
Johnson v. Johnson
385 F.3d 503 (Fifth Circuit, 2004)
Jay Nottingham v. Joel Finsterwald
582 F. App'x 297 (Fifth Circuit, 2014)

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Bluebook (online)
James Edward Probst v. Arturo Beckett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-edward-probst-v-arturo-beckett-txnd-2026.