Walker v. State of Kansas

CourtCourt of Appeals for the Tenth Circuit
DecidedJanuary 29, 2026
Docket25-3189
StatusUnpublished

This text of Walker v. State of Kansas (Walker v. State of Kansas) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Walker v. State of Kansas, (10th Cir. 2026).

Opinion

Appellate Case: 25-3189 Document: 13 Date Filed: 01/29/2026 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT January 29, 2026 _________________________________ Christopher M. Wolpert Clerk of Court EARNEST EUGENE WALKER, JR.,

Plaintiff - Appellant,

v. No. 25-3189 (D.C. No. 5:25-CV-03158-JWL) STATE OF KANSAS; CHRISTIAN E. (D. Kan.) ZOLLER; DAWN L. HELMER; MONA L. FUREST; C. ROBERT BELL; (FNU) NEEDHAM; PAMELA C. PARKER; JOHN DOE (1); JOHN DOE (2); KURT KURNS,

Defendants - Appellees. _________________________________

ORDER AND JUDGMENT * _________________________________

Before MATHESON, PHILLIPS, and McHUGH, Circuit Judges. _________________________________

Earnest Eugene Walker, Jr., proceeding pro se, appeals the district

court’s dismissal of his amended complaint. Walker sued Kansas officials and

his defense attorneys for damages under 42 U.S.C. § 1983 over an allegedly

After examining the briefs and appellate record, this panel has *

unanimously determined that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. But it may be cited for its persuasive value consistent with Federal Rule of Appellate Procedure 32.1 and Tenth Circuit Rule 32.1. Appellate Case: 25-3189 Document: 13 Date Filed: 01/29/2026 Page: 2

illegal sentence. Exercising our jurisdiction under 28 U.S.C. § 1291, we dismiss

Walker’s appeal.

BACKGROUND

In his amended complaint, Walker alleged that a Kansas judge,

prosecutor, and probation officer each violated Walker’s rights under the

Thirteenth and Fourteenth Amendments by imposing an illegal sentence. He

also alleged that his court-appointed and private lawyers violated his rights

under the Sixth and Fourteenth Amendments by failing to correct that illegal

sentence. And Walker alleged that three correctional officers violated his

Eighth Amendment rights while incarcerated.

As required by the Prison Litigation Reform Act, the district court

screened Walker’s amended complaint. Walker v. Kansas, No. 25-3158, 2025

WL 2879444, at *1 (D. Kan. Oct. 9, 2025); see generally 28 U.S.C.

§§ 1915(e)(2)(B), 1915A. The court dismissed the complaint for failing to state

a claim that survived Heck v. Humphrey, 512 U.S. 477 (1994), for lacking

sufficient factual allegations about the correctional officers’ abuse, and for

other § 1983 pleading deficiencies. Walker, 2025 WL 2879444, at *3–5. The

court entered judgment, and Walker appealed.

When he filed his first complaint, Walker was incarcerated at either the

Sedgwick County Adult Detention Facility or the McPherson County Jail. And

when he appealed, Walker was incarcerated at the McPherson County Jail.

2 Appellate Case: 25-3189 Document: 13 Date Filed: 01/29/2026 Page: 3

STANDARD OF REVIEW

We review de novo a dismissal under 28 U.S.C. § 1915(e)(2)(B)(ii) or

§ 1915A for failure to state a claim. Kay v. Bemis, 500 F.3d 1214, 1217 (10th

Cir. 2007); McBride v. Deer, 240 F.3d 1287, 1289 (10th Cir. 2001). We review

those dismissals as we review motions to dismiss for failure to state a claim

under Federal Rule of Civil Procedure 12(b)(6). Kay, 500 F.3d at 1217;

McBride, 240 F.3d at 1289. We ask if the complaint contains “sufficient factual

matter, accepted as true, ‘to state a claim to relief that is plausible on its face.’”

VDARE Found. v. City of Colorado Springs, 11 F.4th 1151, 1158 (10th Cir.

2021) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). Because Walker

proceeds pro se, we liberally construe his pleadings. See Johnson v. Reyna, 57

F.4th 769, 775 (10th Cir. 2023). Because Walker proceeds in forma pauperis,

we must dismiss his appeal if it fails to state a claim on which relief may be

granted. 28 U.S.C. § 1915(e)(2)(B)(ii); see Hafed v. Fed. Bureau of Prisons,

635 F.3d 1172, 1179 (10th Cir. 2011), abrogated in part on other grounds by,

Coleman v. Tollefson, 575 U.S. 532 (2015).

DISCUSSION

We first address Walker’s arguments. He seeks review of the district

court’s Heck ruling. He also seeks review of the court’s dismissal of his

Thirteenth Amendment claim.

We then address Walker’s accumulation of strikes under the PLRA.

3 Appellate Case: 25-3189 Document: 13 Date Filed: 01/29/2026 Page: 4

I. Heck bars Walker’s claims.

Walker emphasizes that he has already sought a declaratory judgment

from the Sedgwick County District Court and otherwise tried to invalidate his

sentence. He asks us to allow his § 1983 claims to proceed to the merits or to

return his case to the Kansas sentencing court. We lack authority to do the

latter, so we address only the former.

Heck bars § 1983 claims that necessarily imply that a sentence is invalid,

unless the § 1983 plaintiff pleads one of these four conditions: (1) the sentence

was “reversed on direct appeal,” (2) it was “expunged by executive order,”

(3) it was “declared invalid by a state tribunal authorized to make such

determination,” or (4) it was “called into question by a federal court’s issuance

of a writ of habeas corpus.” See 512 U.S. at 486–87. When a plaintiff fails to

allege any of these conditions, his § 1983 claims lack “an essential element,”

and the court must dismiss his claims. See Smith v. Vets. Admin., 636 F.3d

1306, 1312 (10th Cir. 2011).

Under Heck, we cannot reach the merits of Walker’s § 1983 claims.

Before the district court, Walker sought money damages for “the extension of

[his] probation sentence and the imposition of [his] prison sentence.” Op. Br. at

2. He did not allege any of the four Heck conditions. So Heck required the

district court to dismiss his claims.

Walker counters that his claims are valid because, under Heck, “[t]he

[e]vidence confirms” that the “sentences are questionable.” Dkt. No. 10 at 2.

4 Appellate Case: 25-3189 Document: 13 Date Filed: 01/29/2026 Page: 5

But this misconstrues Heck’s fourth condition, which applies only when a

sentence is “called into question by a federal court’s issuance of a writ of

habeas corpus.” 512 U.S. at 487 (emphasis added).

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Related

Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
McBride v. Deer
240 F.3d 1287 (Tenth Circuit, 2001)
Kay v. Bemis
500 F.3d 1214 (Tenth Circuit, 2007)
Smith v. Veterans Administration
636 F.3d 1306 (Tenth Circuit, 2011)
Coleman v. Tollefson
575 U.S. 532 (Supreme Court, 2015)
VDARE Foundation v. City of Colorado Springs
11 F.4th 1151 (Tenth Circuit, 2021)
Johnson v. Reyna
57 F.4th 769 (Tenth Circuit, 2023)

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Walker v. State of Kansas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walker-v-state-of-kansas-ca10-2026.