Adams v. Louisiana Department of Corrections

CourtDistrict Court, M.D. Louisiana
DecidedMay 28, 2024
Docket3:22-cv-00020
StatusUnknown

This text of Adams v. Louisiana Department of Corrections (Adams v. Louisiana Department of Corrections) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Louisiana Department of Corrections, (M.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

COREY MARQUEE ADAMS CIVIL ACTION VERSUS 22-20-SDD-RLB LOUISIANA DEPARTMENT OF CORRECTIONS, ET AL.

RULING This matter comes before the Court on the Motion to Dismiss pursuant to 12(b)(5)1 filed by Defendant Charles Tolbert (“Defendant Tolbert”), through the Assistant Attorney General. Plaintiff, Corey Marquee Adams (“Plaintiff”) filed an Opposition,2 to which Defendant filed a Reply.3 For the reasons set forth below, the Court will deny Defendant’s motion. I. BACKGROUND AND PROCEDURAL FACTS

This motion challenges the Amended Complaint4 filed by Plaintiff, who is incarcerated and was proceeding pro se at the time of filing. He alleges, inter alia, that Defendant Tolbert and several other named defendants violated the American Disabilities Act, 42 U.S.C 12101 (the “ADA”), and acted with deliberate indifference in violation of his Eighth Amendment rights.5 With respect to Defendant Tolbert, Plaintiff alleges that on October 20, 2020, Defendant Tolbert was a sergeant in the Louisiana State Penitentiary (“LSP”), and Defendant “refused to call for help or otherwise assist” Plaintiff while Plaintiff

1 Rec. Doc. 131. 2 Rec. Doc. 133. 3 Rec. Doc. 136. 4 Rec. Doc. 104. 5 Id. “was bleeding out in his cell from lacerations caused by an attempted suicide.”6 When Plaintiff filed his Original Complaint, Plaintiff did not know Defendant’s actual name and identified him as “Toby” without any other identifying information.7 On June 12, 2023, Plaintiff sought leave to amend his complaint once he identified “Toby” as Defendant Tolbert through the course of litigation.8 The Court granted this motion, and on September

12th, the Court ordered the named defendants to file the last known address of Defendant Tolbert under seal within seven days.9 Additionally, Plaintiff was permitted an additional 45 days to effect service upon Defendant Tolbert.10 On September 14th, the Defendants filed a Notice of Compliance under seal containing the last known address of Defendant Tolbert.11 Thereafter, Plaintiff retained counsel, and they enrolled in this matter on October 4th.12 On December 8th, Defendant Tolbert filed the pending motion because he was never served with Plaintiff’s complaint.13 II. LAW AND ANALYSIS A. Rule 12(b)(5)

If a plaintiff fails to properly effectuate service, the defendant may seek to dismiss the plaintiff's complaint under Rule 12(b)(5).14 “A motion to dismiss pursuant to Rule 12(b)(5) turns on the legal sufficiency of the service of process.”15 The burden of

6 Rec. Docs. 104 and 133. 7 Rec. Doc. 1-1. 8 Rec. Doc. 79. 9 Rec. Doc. 98. 10 Id. 11 Rec. Doc. 105. 12 Rec. Doc. 115. 13 Rec. Doc. 132. 14 See Fed. R. Civ. P. 12(b)(5) (authorizing a court to dismiss a civil action when service of process is inadequate). 15 Ceasar v. Louisiana Bd. of Ethics, 2018 WL 2090184, at *4 (M.D. La. May 4, 2018) (quoting Holly v. Metro. Transit Auth., 213 Fed.Appx. 343, 344 (5th Cir. 2007)). demonstrating the validity of service when an objection is made lies with the party making service.16 When a challenge made to the adequacy of service of process, the serving party bears the burden of proving the validity of service or the existence of good cause for failing to effect service in a timely manner.17 The fact that the plaintiff is pro se does not excuse the failure to properly effect service of process.18

To establish good cause for failing to timely effect service, a plaintiff has the burden of demonstrating “at least as much would be required to show excusable neglect. . . .”19 “Simple inadvertence or mistake of counsel or ignorance of the rules usually does not suffice. . . .”20 In addition, “some showing of ‘good faith on the part of the party seeking an enlargement and some reasonable basis for noncompliance within the time specified’ is normally required.”21 It is “irrelevant that the defendant not served within the 120–day period later finds out about the suit or is in fact later served, so long as there was not good cause for the failure to serve within the 120 days.”22 A plaintiff who is incarcerated and proceeding pro se is “entitled to rely upon

service by the U.S. Marshal to properly effect service of process, where such fault is through no fault of the litigant.”23 However, if the failure to timely effect service is due to the “dilatoriness or fault” of the plaintiff, he will be unable to show good cause for such

16 Id (citing Holly, 213 Fed. Appx. at 344). 17 Id (citing System Sign Supplies v. U.S. Dept. of Justice, 903 F.2d 1011, 1013 (5th Cir. 1990); Aetna Business Credit, Inc. v. Universal Décor & Interior Design, Inc., 635 F.2d 434, 435 (5th Cir. 1990)). 18 Id (citing System Signs Supplies, 903 F.2d at 1013; Dupre v. Touro Infirmary, 235 F.3d 1340 (5th Cir. 2000) (unpub'd)). 19 Mayeaux v. McKee, 2014 WL 7186275, at *2–3 (M.D. La. Dec. 16, 2014) (quoting Winters v. Teledyne Movible Offshore, Inc., 776 F.2d 1304, 1306 (5th Cir.1985)). 20 Id (quoting Winters, 776 F.2d at 1306). 21 Id (quoting Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 1165 (1969)). 22 Id (quoting Winters, 776 F.2d at 1305–6). 23 Rochon v. Dawson, 828 F.2d 1107, 1110 (5th Cir. 1987). failure.24 Defendant Tolbert requests dismissal because Plaintiff failed to serve him within the time permitted by the Court’s Order.25 Defendant argues that, although he timely filed his last known address into the record, Plaintiff did not effect service.26 Plaintiff concedes that he did not effect service but argues good cause exists because, at the time to effect

service, Plaintiff was proceeding pro se and relied on the Clerk of the Court and the U.S. Marshal to effect service, and the government personnel failed to do so.27 The Fifth Circuit has considered cases where a pro se incarcerated plaintiff has relied upon service by the U.S. Marshal. In Rochon v. Dawson, the U.S. Marshals failed to properly effect service, and the court had to decide whether the failure of the U.S. Marshals was due to any dilatoriness or fault by the plaintiff. The Circuit court explained that, “[at] a minimum a plaintiff should request service upon the appropriate defendant and attempt to remedy any apparent service defects of which a plaintiff has knowledge.”28 The Circuit court found that the district court provided notice to the plaintiff that the

defendant was never served. Despite this notice, the plaintiff never requested that the U.S Marshal properly serve the defendant. The Circuit court found that the plaintiff was penalized not because of the U.S. Marshal, but because of his own “inaction or dilatoriness.”29 The Fifth Circuit came to a different conclusion in Lindsey v. U.S. RR Retirement Board. In that case, the Fifth Circuit found that good cause was shown because the

24 Id. 25 Rec. Doc. 131. 26 Rec. Doc. 131-1, pp. 3–4. 27 Rec. Doc. 133, pp. 6–7. 28 828 F.2d at 1109–10 (5th Cir. 1987). 29 Id.

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