Brown v. LA Dept of Safety & Corrections

CourtDistrict Court, W.D. Louisiana
DecidedMay 22, 2025
Docket1:23-cv-01089
StatusUnknown

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

Bluebook
Brown v. LA Dept of Safety & Corrections, (W.D. La. 2025).

Opinion

aa UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA ALEXANDRIA DIVISION

DALE BROWN #53074/418906,, CIVIL DDOCKET NNO. 1:23--CV--01089 PPlaintiff SSEC P

VERSUS JUDGE EDWARDS

LA DEPT OF SAFETY & MAGISTRATE JUDGE PEREZ--MONTES CCORRECTIONS ET AL, Defendants

REPORT AND RECOMMENDATION Before the Court is a Motion for Summary Judgment (ECF No. 31) seeking dismissal of a civil rights Complaint (42 U.S.C. § 1983) filed by pro se Plaintiff Dale Brown (“Brown”). Brown is incarcerated at the Raymond Laborde Correctional Center (“RLCC”) in Cottonport, Louisiana. He alleges the denial of religious freedoms in violation of the constitution and laws of the United States. Because Brown cannot recover compensatory damages and Defendants are entitled to judgment as a matter of law, the Motion for Summary Judgment should be GRANTED. I. Background Brown alleges that he was notified by security that he was scheduled for a “mandatory callout at the chapel.” ECF No. 1 at 2. Upon arrival at the chapel, he was met by Chaplain Moore, Captain Gunn, and Col. Bordelon. Brown was ushered into the chaplain’s office for a “Board Hearing.” Chaplain Moore handed Brown a “revocation paper” informing Brown that his religious hair exemption had been revoked. Brown was told that his beard would be cut off “one way or another.” at 3.

Brown was then escorted to the showers where he was “shackled and forcibly shaved” by Lt. Bordelon. He was written up for aggravated disobedience and sanctioned with two days of room confinement. Brown seeks money damages for the violation of his constitutional rights. Brown’s claims against RLCC and James Leblanc have been denied and dismissed with prejudice; his claims against the Department of Corrections (“DOC”) have been dismissed for lack of jurisdiction; and his claim for the termination of employees has

been denied. ECF No. 9. DOC Regulation No. PS-E-1 provides the policy for Religious Faith-Based Programs and Services. ECF No. 31-4. Subsection 7.G.(1) instructs that each warden “shall ensure that offenders have the opportunity to participate in practices of their religious faith that are deemed essential by the faith’s governing judicatory, limited only by documentation showing threat to the safety of persons involved in the practice

of the faith or that the practice itself disrupts order in the institution.” ECF No. 31- 4 at 5. In determining what constitutes legitimate religious practices, “the Warden or designee shall consider whether there is a body of literature stating religious principles that support the practices and whether the practices are recognized by a group of persons who share common ethical, moral, or intellectual views. RLCC adopted the DOC’s Policy. ECF No. 31-3. Pursuant to the RLCC Offender Personal Grooming/Group Identification Policy #03-03-004, facial hair “shall be limited to a well-groomed moustache and/or a full beard not to exceed one half inches in length.” ECF No. 31-5 at 3. RLCC’s facial

hair policy is identical to DOC Regulation No. IS-C-4. ECF No. 31-6 at 3. Brown requested a religious exemption seeking to grow his beard unrestrained, without regard to length, while keeping his head shaved, purportedly in conjunction with his identification as a Rastafarian “Beardman.” III. Law and Analysis Under Federal Rule of Civil Procedure 56(a), a court “shall grant summary judgment if the movant shows that there is no genuine dispute as to any material

fact and the movant is entitled to judgment as a matter of law.” The moving party bears the initial burden of informing the court of the basis for its motion by identifying portions of the record which highlight the absence of genuine issues of material fact. , 954 F.2d 1125, 1132 (5th Cir. 1992); Fed. R. Civ. P. 56(c)(1) (“A party asserting that a fact cannot be . . . disputed must support the assertion by . . . citing to particular parts of materials in the record . . . .”).

A fact is “material” if proof of its existence or nonexistence would affect the outcome of the lawsuit under applicable law in the case. , Inc., 477 U.S. 242, 248 (1986). A dispute about a material fact is “genuine” if the evidence is such that a reasonable fact finder could render a verdict for the nonmoving party. When a motion for summary judgment is made and supported, an adverse party may not rest on mere allegations or denials but must set forth specific facts showing a genuine issue for trial. , 63 F.3d 429, 433

(5th Cir. 1995). AA. Brown may not recover compensatory damages.

Brown seeks compensatory damages under the First Amendment, enforceable against state officials through the Fourteenth Amendment, and the Eighth Amendment.1 However, 42 U.S.C. § 1997e(e) provides that no federal civil action may be brought by a prisoner for mental or emotional injury without a prior showing of physical injury. , 23-CV-492, 2024 WL 4575368, at *3 (W.D. La. 2024), , 2024 WL 4573601 (W.D. La. 2024) (citing 42 U.S.C. § 1997e(e)). This requirement applies to all federal civil actions in which a prisoner alleges a constitutional violation, including First Amendment claims that are not usually accompanied by physical injury. (citing , 404 F.3d 371, 374-75 (5th Cir. 2005)) (“Section 1997e(e) applies to all federal civil actions in which a prisoner alleges a constitutional violation, making compensatory damages

for mental or emotional injuries non-recoverable, absent physical injury.”); , 529 F.3d 599, 605–06 (5th Cir. 2008); , 277 F. App’x 491 (5th Cir. 2008). Brown does not allege that he suffered any physical injury when his beard was shaved.

1 Because the Court has dismissed his request that Defendants’ employment be terminated (ECF No. 9), Brown’s claim for compensatory damages is all that remains. Even if his claim was not barred by § 1997e(e), Defendants would be entitled to judgment as a matter of law. A prison policy or practice will not be found in violation of the First Amendment if it is reasonably related to a legitimate penological

objective of the facility. , 21-CV- 733, 2022 WL 4593085, at *2 (M.D. La. 2022), , 82 F.4th 337 (5th Cir. 2023) (citing , 834 F.2d 481, 487–87 (5th Cir. 1987)). This general statement of the law has been applied to regulations that required Rastafarians to cut their hair, even though keeping one’s hair unshorn and unwashed is a tenet of the Rastafari religion. , 961 F.2d 77 (5th Cir. 1992); , 69 F.3d 22, 25 (5th Cir. 1995).

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Brown v. LA Dept of Safety & Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-la-dept-of-safety-corrections-lawd-2025.