Alan Jackson Schmidt v. Rankin County, Mississippi, et al.

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION

ALAN JACKSON SCHMIDT,

Plaintiff,

v. CAUSE NO. 3:25-CV-909-CWR-ASH

RANKIN COUNTY, MISSISSIPPI, et al.,

Defendants.

ORDER Defendant Rankin County, Mississippi (“Rankin County”) filed a motion to dismiss Plaintiff Alan Jackson Schmidt’s claims against Christian Dedmon, Hunter Elward, Daniel Opdyke, Brett McAlpin, and John Does in their official capacities since those claims are duplicative of the claims against Rankin County. Docket No. 4 at 1. Under 42 U.S.C. § 1983, Rankin County also seeks to dismiss Plaintiff’s claims for punitive damages against the County. Id. In his response and corresponding memorandum, Plaintiff confessed that he cannot bring these claims as a matter of law. Docket Nos. 11-12. For this reason and the current state of the law, the Court grants Defendant Rankin County’s motion. See Moore v. Jackson Pub. Sch. Dist., No. 3:21-CV-531-CWR-FKB, 2021 WL 5352130, at *2 (S.D. Miss. Nov. 16, 2021) (“[C]ourts faced with claims against both a government employer and an employee in his official capacity typically dismiss the claims against the individual defendant to avoid redundancy.”) (citing Burroughs v. City of Laurel, No. 2:19-CV-48-KS-MTP, 2019 WL 4228438, at *5 (S.D. Miss. Sept. 5, 2019)); Moore v. LaSalle Mgmt. Co., 41 F.4th 493, 512 (5th Cir. 2022) (“[M]unicipal immunity from punitive damages survived § 1983.”). SO ORDERED, this the 11th day of August, 2026.

s/ Carlton W. Reeves UNITED STATES DISTRICT JUDGE