Degollado v. City of Port Lavaca, Texas

CourtDistrict Court, S.D. Texas
DecidedMarch 31, 2025
Docket6:23-cv-00014
StatusUnknown

This text of Degollado v. City of Port Lavaca, Texas (Degollado v. City of Port Lavaca, Texas) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Degollado v. City of Port Lavaca, Texas, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT April 01, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk VICTORIA DIVISION ALEXANDRA DEGOLLADO, § FADED SMOKE SHOP, LLC, and § DANIEL HERRERA, JR., § § Plaintiffs, § § v. § Civil Action No. 6:23-CV-00014 § CITY OF PORT LAVACA, TEXAS, § COLLIN RANGNOW, KYLE CURTIS, § KAREN NEAL, ADAM BEARD, JAVIER § RAMOS, MAXWELL DUKE, MARIA § MORENO, DEVON MOORE, ERIC § SALLES, and JUSTIN KLARE, § § Defendants. § MEMORANDUM OPINION AND ORDER

Alexandra Degollado opened Faded Smoke Shop, LLC (“Faded”) in Port Lavaca, Texas, and started selling a wide range of hemp products. Shortly after opening the shop, she learned from customers that the police were investigating her, the business, and her employee, Daniel Herrera, Jr. Police officers had gone undercover as customers, bought some of Degollado’s hemp products, and had them tested to determine whether they were the “legal” kind or not. Eventually, officers obtained a search-and-arrest warrant. With a warrant in hand, officers raided the shop, seized various hemp products, arrested Herrera, and arrested Degollado when she turned herself in two days after the raid. Police issued press releases, Facebook posts, and other statements describing the allegedly illegal activity of Degollado, Herrera, and Faded. Degollado and Herrera were indicted for possession with intent to distribute a controlled substance, but after about eight months, their cases were dismissed. The Port Lavaca Police Department returned several of Degollado’s items, except for around $14,000 worth of hemp products that

Degollado alleges are legal. Degollado, Herrera, and Faded sued on February 9, 2023, alleging various constitutional claims under 42 U.S.C. § 1983, along with several state-law claims. After the Court dismissed Plaintiffs’ Original Complaint without prejudice, they amended it, asserting many of the same constitutional claims under Section 1983 and one state-law malicious-prosecution claim against Defendants. Defendants now move to dismiss the

Amended Complaint under Rules 12(b)(1) and 12(b)(6), arguing that Plaintiffs’ claims fail because of qualified immunity, immunity under the Texas Tort Claims Act, and purported pleading deficiencies. Plaintiffs have not responded. After careful review of the Motion, the record, and any applicable law, the Court finds that the Defendant’s Motion to Dismiss Plaintiffs’ First Amended Complaint, (Dkt. No. 19), should be

GRANTED. I. BACKGROUND1 Before addressing the specific facts, it helps to understand the difference between hemp and marijuana, as well as the recent changes to the law governing them.

1 For purposes of addressing this Motion, the Court accepts all factual allegations in the operative complaint as true and views them in the light most favorable to the nonmovant. See White v. U.S. Corrs., LLC, 996 F.3d 302, 306–07 (5th Cir. 2021). A. HEMP AND MARIJUANA GENERALLY Hemp and marijuana come from the same plant species, Cannabis sativa L., but they are genetically distinct and differ in chemical composition and use. Renée Johnson,

Defining Hemp: A Fact Sheet, Congress.gov (Mar. 22, 2019), https://www.congress.gov/ crs-product/R44742; Cannabis (Marijuana), Nat’l Inst. on Drug Abuse (Sept. 24, 2024), https://nida.nih.gov/research-topics/cannabis-marijuana [https://perma.cc/EPL7- 9KNW].2 The cannabis plant contains a variety of natural chemical compounds known as

cannabinoids, including tetrahydrocannabinol (“THC”) and cannabidiol (“CBD”). FDA and Cannabis: Research and Drug Approval Process, U.S. Food & Drug Admin. (Feb. 24, 2023), https://www.fda.gov/news-events/public-health-focus/fda-and-cannabis- research-and-drug-approval-process. Delta-9 THC, the most abundant type of THC in cannabis, can temporarily alter a person’s mood, thoughts, and perceptions. Nat’l Inst.

on Drug Abuse, supra. CBD, on the other hand, is a nonintoxicating cannabinoid with no mind-altering effects. Id.; Cannabis and Public Health: About CBD, Ctr. for Disease Control (Jan. 31, 2025), https://www.cdc.gov/cannabis/about/about-cbd.html [https:// perma.cc/V6AK-7XXS]. It is commonly used to reduce anxiety, improve sleep, alleviate pain, and mitigate inflammation. See Peter Grinspoon, Cannabidiol (CBD): What We Know and What We Don’t, Harvard Health Publ’g (Apr. 4, 2024), https://www.

2 See also Hemp Production Program Questions and Answers, U.S. Dep’t of Agric. (Apr. 25, 2022), https://www.ams.usda.gov/rules-regulations/hemp/questions-and-answers [https:// perma.cc/K5XV-7E64]. health.harvard.edu/blog/cannabidiol-cbd-what-we-know-and-what-we-dont-20180824 14476 [https://perma.cc/6VR3-QNBP].

While marijuana and hemp come from the same general plant species, the terms are not interchangeable. Marijuana typically refers to cannabis grown to produce high levels of THC (between 10–30%) and is a psychotropic drug for medicinal or recreational purposes. Johnson, supra. Hemp is a variety of the cannabis plant grown to contain very low, non-intoxicating amounts of Delta-9 THC (less than 0.3%) and is largely cultivated for industrial products, dietary supplements, or CBD extraction. Id.; Nat’l Inst. on Drug

Abuse, supra; Ctr. For Disease Control, supra. B. RECENT LEGAL CHANGES Based on this distinction, Congress passed the Agriculture Improvement Act in 2018, which removed “hemp” from the definition of “marijuana” under the Controlled Substances Act3 and defined “hemp” as “the plant Cannabis sativa L. . . . with a [Delta-9 THC] concentration of not more than 0.3 percent.”4

Following in the federal government’s footsteps, Texas partially legalized hemp and hemp-derived products.5 Like the federal definition, see 7 U.S.C. § 1639o(1), Texas

3 Agriculture Improvement Act of 2018, Pub. L. No. 115-334, § 12619(a), 132 Stat. 4490, 5018 (2018) (codified at 21 U.S.C. § 802(16)(B)(i)). 4 Agriculture Improvement Act of 2018, Pub. L. No. 115-334, § 297A, 132 Stat. 4490, 4908 (2018) (codified at 7 U.S.C. § 1639(o)(1)). 5 See Act of June 10, 2019, 86th Leg., R.S., ch. 764, § 7, 2019 Tex. Gen. Laws 2085, 2099; see also Tex. Health & Safety Code § 443.204(1) (stating that “hemp-derived cannabinoids, including cannabidiol [CBD], are not considered controlled substances or adulterants”); Tex. Health & Safety Code § 481.002(5) (excluding “hemp” from the definition of a “controlled substance”); Tex. Health & Safety Code § 481.002(26) (excluding “hemp” from the definition of “marijuana”). defined “hemp” as “the plant Cannabis sativa L. and any part of that plant, including the seeds of the plant and all derivatives, extracts, cannabinoids, isomers, acids, salts, and

salts of isomers, whether growing or not, with a [Delta-9 THC] concentration of not more than 0.3 percent.” Tex. Agric. Code § 121.001; see also 25 Tex. Admin. Code § 300.101(1) (defining the “acceptable hemp THC level” as a “[Delta-9 THC] content concentration level . . . that, when reported with the accredited laboratory’s measurement of uncertainty, produces a distribution or range that includes a result of 0.3 percent or less”). C.

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