Burnell LaFrance v. Merchant Security Service et al

CourtDistrict Court, W.D. Louisiana
DecidedSeptember 23, 2025
Docket6:24-cv-01302
StatusUnknown

This text of Burnell LaFrance v. Merchant Security Service et al (Burnell LaFrance v. Merchant Security Service et al) 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
Burnell LaFrance v. Merchant Security Service et al, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

BURNELL LAFRANCE CASE NO. 6:24-CV-01302

VERSUS JUDGE DAVID C. JOSEPH

MERCHANT SECURITY SERVICE ET AL MAGISTRATE JUDGE DAVID J. AYO

REPORT AND RECOMMENDATION

Before the Court are motions to dismiss filed by defendants Dixie RV Superstores of Acadiana, LLC (“Dixie”) (Rec. Doc. 10) and Merchant Security Service (“Merchant”) (Rec. Doc. 14). Pro se plaintiff Burnell LaFrance opposes these motions. (Rec. Docs. 12, 16). These motions were referred to the undersigned magistrate judge for review, report, and recommendation in accordance with the provisions of 28 U.S.C. §636 and the standing orders of this Court. Considering the evidence, the law, and the parties’ arguments, and for the reasons explained below, the Court recommends that the instant motions be GRANTED IN PART and DENIED IN PART AS MOOT. Factual Background After review of the record, this Court surmises that LaFrance was employed by Merchant as a security guard at Dixie’s RV lot. (Rec. Doc. 1). LaFrance filed the instant suit on September 20, 2024, alleging that he sustained injuries to his head and neck on December 27, 2023 when a golf cart he was using during the performance of his duties at Dixie tipped over and fell on top of him. (Id. at p. 6). LaFrance further alleges that Merchants refused to file a workers’ compensation injury report and eventually fired him on February 27, 2024, subsequently refusing to give him all of the pay that he had earned. (Rec. Doc. 6). LaFrance filed an amended complaint on February 3, 2025, in which he alleges that his claims arise under federal law and that the amount in controversy exceeds $75,000.00. (Id. at p. 2). LaFrance’s suit names as defendants Merchant, Dixie, and the golf cart manufacturer Evolution Golf Cart (“Evolution”). (Id. at pp. 1–2). This Court previously granted LaFrance’s motion to proceed in forma pauperis and later granted his motion to effect service via the United States Marshal. (Rec. Docs. 3, 9). While the record does not contain evidence of service by the Marshal, defendants Merchant and Dixie filed responsive pleadings in the form of the instant motions. (Rec. Docs. 10, 14).

No appearance has been made by defendant Evolution. Applicable Standards

The law governing federal jurisdiction is well settled:

Federal courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute…which is not to be expanded by judicial decree. It is to be presumed that a cause of action lies outside this limited jurisdiction…and the burden of establishing the contrary rests upon the party asserting jurisdiction.

Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375, 377 (1994) (internal citations omitted). Federal district courts possess two types of original subject matter jurisdiction. Federal question jurisdiction authorizes district courts to preside over “all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. Diversity jurisdiction permits district courts to hear cases in which there is diversity of citizenship and the amount in controversy exceeds $75,000.00, exclusive of costs and interest. 28 U.S.C. § 1332. Section 1332 requires “complete diversity,” which is to say that no party on one side of the controversy may share citizenship with any party on the other side of the controversy. Harvey v. Grey Wolf Drilling Co., 542 F.3d 1077, 1079 (5th Cir. 2008) (citing Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267, 2 L.Ed. 435 (1806), McLaughlin v. Miss. Power Co., 376 F.3d 344, 353 (5th Cir. 2004)). Absent a jurisdictional challenge, a plaintiff’s allegation of jurisdiction meeting the statutory requirements is a sufficient basis upon which the court may proceed. When challenged, however, the plaintiff bears the burden of demonstrating that the alleged jurisdiction does, in fact, exist. Ballew v. Cont’l Airlines, Inc., 668 F.3d 777, 781 (5th Cir. 2012); Guerrero v. State Farm Mut. Auto. Ins. Co., 181 F.3d 97, 97 (5th Cir. 1999).

Where motions before a district court seek dismissal for lack of jurisdiction and upon other grounds, the court must address its jurisdiction first, before addressing any attack on the merits. Willoughby v. U.S. ex rel. U.S. Dep’t of the Army, 730 F.3d 476, 479 (5th Cir. 2013). “‘When courts lack subject matter jurisdiction over a case, they lack the power to adjudicate the case’ and must dismiss it.” Goodrich v. United States, 3 F.4th 776, 779 (5th Cir. 2021) (quoting Nat’l Football League Players Ass’n v. Nat’l Football League, 874 F.3d 222, 225 (5th Cir. 2017). Analysis The instant motions filed by Dixie and Merchant each allege a lack of subject matter jurisdiction over LaFrance’s claims. (Rec. Docs. 10, 14). Specifically, the motions point out that LaFrance’s Amended Complaint alleges no facts upon which this Court could infer a claim arising under federal law, negating the prospect of federal question jurisdiction. The motions further argue that LaFrance, Dixie, and Merchant are Louisiana citizens, destroying complete diversity and, thus, negating the prospect of diversity jurisdiction. Review of the Amended Complaint affirms these jurisdictional arguments. LaFrance’s Amended Complaint asserts tort claims under Louisiana law arising from his employment with Merchant. (Rec. Doc. 6). Although the Amended Complaint specifically

alleges federal jurisdiction based on the existence of a federal question, as well as an amount in controversy exceeding the diversity jurisdiction threshold of $75,000.00, these bare assertions are insufficient, particularly in light of defendants’ jurisdictional challenges. As a pro se litigant, LaFrance’s Amended Complaint is subjected to the same jurisdictional standards applied in all cases, but his pleadings must be liberally construed. Erickson v. Pardus, 551 U.S. 89, 94 (2007). While the pleading need not cite a federal statute or rule by name, its jurisdictional basis must be alleged “affirmatively and distinctly.” Ill. Cent. Gulf R.R. Co. v. Pargas, Inc., 706 F.2d 633, 636 (5th Cir. 1983). Review of the Amended

Complaint discloses no factual allegations which, liberally construed, state a claim arising under federal law. Turning to diversity jurisdiction, this Court agrees with defendants that complete diversity does not exist in this matter. LaFrance alleges he is a resident and citizen of Lafayette, Louisiana. (Rec. Doc. 6 at p. 1). Dixie offers the Declaration of Stephen L. Guidry, Jr., Dixie’s President and Chief Operating Officer, attesting that Dixie is a Louisiana limited liability company with three members, all of whom are Louisiana residents. (Rec. Doc. 10- 2). Merchant offers the Declaration of Eric L.

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Related

Harvey v. Grey Wolf Drilling Co.
542 F.3d 1077 (Fifth Circuit, 2008)
Strawbridge v. Curtiss
7 U.S. 267 (Supreme Court, 1806)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ballew v. Continental Airlines, Inc.
668 F.3d 777 (Fifth Circuit, 2012)
Goodrich v. United States
3 F.4th 776 (Fifth Circuit, 2021)

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