Jerry Jeron Daniels v. Peter Damiter; Kathy J. Brittain; Jennifer Newberry; Keri Moore; D. Varner; Beth Lazusky; Melissa Morgain, SCI – Frackville Records Supervisor
March 30, 2026·25-3173·Panel Decision·By Aisha Johnson
The United States Court of Appeals for the Third Circuit summarily affirmed a district court order denying a state inmate's motion for the appointment of counsel. The appellate court found no abuse of discretion in the lower court's refusal to grant relief under Rule Sixty-B of the Federal Rules of Civil Procedure.
State inmate Jerry Daniels filed a civil action alleging illegal incarceration and involuntary slavery. The district court dismissed the action as barred by Heck v. Humphrey. Nearly a year later, Daniels requested the appointment of counsel and sought relief from judgment under Rule Sixty-B, which the district court denied. Daniels appealed in forma pauperis.
The court’s reasoning
The court reviewed the denial of the Rule Sixty-B motion and the motion for appointment of counsel for abuse of discretion. The court found that Daniels’ argument regarding the absence of an arrest warrant did not establish that his conviction or sentence had been invalidated as required by Heck v. Humphrey. Consequently, the district court did not abuse its discretion in denying relief or counsel.
What it means going forward
The decision reinforces that a prisoner cannot use Rule Sixty-B to circumvent the Heck v. Humphrey bar on civil claims challenging the validity of a conviction without first having that conviction invalidated.
