Deloune v. Mahaffey

CourtDistrict Court, M.D. Louisiana
DecidedJuly 24, 2025
Docket3:24-cv-00634
StatusUnknown

This text of Deloune v. Mahaffey (Deloune v. Mahaffey) 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
Deloune v. Mahaffey, (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

DEMONDRA DELOUNE CIVIL ACTION

VERSUS 24-CV-00634-SDD-SDJ DANIEL MAHAFFEY, ET AL.

RULING Before the Court is a Motion for Entry of Preliminary Default and for Hearing on Confirmation of Default1 filed by Plaintiff Demondra Deloune (“Deloune”) against Defendant Col. Bentley (“Col. Bentley”),2 for failing to file an answer or any responsive pleadings in this case. Defendants the State of Louisiana, through the Department of Public Safety and Corrections (“DPSC”) and “Capt. Daniel Mahaffey” (“Mahaffey”) in his individual capacity, oppose on the basis that service was not accepted for “Col. Bentley” and that the proper defendant Frazier Bendily (“Bendily”) was never served.3 Deloune’s motion is denied for the following reasons. I. FACTS AND PROCEDURAL BACKGROUND Deloune filed suit on June 14, 2024, under 42 U.S.C. §1983 in the Twentieth Judicial District Court, Parish of East Feliciana, alleging excessive force, battery, and retaliation in violation of his First Amendment and Fourteenth Amendment constitutional rights, in addition to state law claims of intentional and/or negligent acts or omissions,

1 Rec. Doc. 22. 2 With this motion pending, the Court granted Deloune leave to amend the caption of the case and named Defendant from “Col. Bentley” to Col. Frazier Bendily (“Bendily”). Rec. Doc. 40. There, however, the Court did not take up the issue of relation back as to Deloune’s request for entry of preliminary default as to “Col. Bentley.” Id. at p. 3. 3 Rec. Doc. 26. intentional infliction of emotional distress, and respondeat superior.4 Deloune alleges the incident took place on September 20, 2023 while housed at Dixon Correctional Institute (“DCI”) in Jackson, Louisiana.5 Originally, Deloune named as Defendants the State of Louisiana, through the Department of Public Safety and Corrections (“DPSC”), “Capt. Daniel Mahaffey” in his individual capacity, and “Col. Bentley” in his individual capacity.6

Deloune served DPSC with citation, through Rhonda Weldon (“Weldon”) at Department of Corrections (“DOC”), on July 11, 2024.7 On August 2, 2024, DPSC and Mahaffey removed the action under this Court’s federal question jurisdiction, alleging that all served Defendants consented to removal.8 On August 30, 2024, DPSC and Mahaffey answered the Complaint.9 Deloune originally sought an extension of time to serve “Col. Bentley” allegedly on the basis that Deloune’s counsel, Ms. Donna Grodner (“Grodner”) “was relying upon the service returns and confusing information from the state court clerk’s office.”10 Deloune then withdrew the motion for extension, stating “[h]aving retrieved the actual service returns, Col. Bentley was served.”11

4 Rec. Doc. 12. Deloune affirmatively alleges that no §1983 claims are asserted against DPSC. Rec. Doc. 12 at p. 42. 5 Rec. Doc. 12 at p. 32. Deloune has since been released. Id. at pp. 32-33. 6 Id. at pp. 32-33. 7 Rec. Doc. 1 at p. 1. The citation in the record was directed to DPSC, the Office of Risk Management (“ORM”), and the Attorney General. Rec. Doc. 12 at p. 31. The service return filed in the record shows a date of service of July 3, 2024, filed July 19, 2024. Rec. Docs. 12 at p. 31, 16-5. The service return does not reflect which party was served on July 3, 2024. Deloune contends the Office of Risk Management was served via facsimile on July 10, 2024, and that the Attorney General’s office was served with citation by the sheriff on July 3, 2024. Rec. Doc. 25-2 at p. 1. Regardless, the only service the parties appear to dispute in this motion is regarding “Col. Bentley.” 8 Rec. Doc. 1. Defendants make no reference as to the status of service of “Col. Bentley” in the Notice of Removal other than to state that “Defendants are in the process of requesting a copy of all process, pleadings, and orders served upon the Defendants in the State Court action[.]” Rec. Doc. 1 at p. 2. 9 Rec. Doc. 9. 10 Rec. Doc. 21. 11 Id. On November 4, 2024, Deloune filed the instant motion for entry of preliminary default under Fed. R. Civ. P. 55(a) and hearing on confirmation of default against “Col. Bentley” for failure to answer or file any responsive pleadings.12 Relatedly, in December 6, 2024, with the instant motion pending, Deloune sought relief to amend the caption of the case and name of “Col. Bentley” to Bendily.13 Therein, Deloune alleged Bendily is a

DOC employee who was employed on September 20, 2023 and who was employed “when his agent for service of process [ ] Weldon was served with process.”14 DPSC and Mahaffey opposed both the Motion for Entry of Default Judgment as to “Col. Bentley” and the Motion to Amend.15 DPSC and Mahaffey, however, did not object to the “isolated amendment of the name and caption,” and only raised an objection to the extent that the amendment would retroactively apply to Deloune’s instant motion for entry of preliminary default.16 Deloune replied that Weldon is the proper agent and that she was served with a citation and process.17 He further contends that, although there may have initially been

some confusion, it became clear that “Col. Bentley” was “Col. Bendily.”18 Deloune maintains that the authorized agent for service on Bendily was served and that he has yet to file an answer.19

12 Rec. Doc. 22. 13 Rec. Doc. 25. 14 Rec. Doc. 25-2 at p. 1. 15 Rec. Doc. 26. 16 Id. at p. 1. 17 Rec. Doc. 29 at p. 1. 18 Id. 19 Id. On February 26, 2024, Deloune moved to withdraw the Motion for Entry of Preliminary Default. Rec. Doc. 30. However, on March 5, 2025, Deloune withdrew his Motion to Withdraw the Motion for Entry of Preliminary Default, stating that at a February 26, 2025 Rule 37.1 conference, the State advised that if the preliminary default was withdrawn that a responsive pleading would be filed for Col. Frazier Bendily. But upon moving to withdraw the preliminary default, Deloune claims that “the State is refusing to make an appearance for Bendily.” Rec. Docs. 31, 34. The Court granted Deloune’s Motion to Amend the caption of the case and changed the name of Defendant “Col. Bentley” to Bendily, but did not take up the issue of relation back as to the pending Motion for Entry of Preliminary Default.20 Thus, the issues before the Court are whether the amendment of “Col. Bentley” to Bendily relates back to Deloune’s Motion for Entry of Preliminary Default, and whether Deloune perfected

service as to Bendily by service of process to “Col. Bentley” through Weldon, entitling him to an entry to default. II. LAW AND ANALYSIS A. Relation Back As noted above, the Court allowed Deloune to amend named defendant “Col. Bentley” to “Frazier Bendily” on the basis that all factors under Fed. R. Civ. P. 15(a) weighed in favor of Deloune.21 “Email communications between the parties showed that all agree Col. Bentley is not the correct party, and Frazier Bendily is.”22 Remaining before the Court is the issue of whether the amendment relates back to the instant motion before

the Court. The addition of a new defendant commences the lawsuit as to that defendant.23 Under federal law, adding a new defendant generally does not relate back to the filing of the original complaint unless Rule 15(c)(1)(C) provides so.24 This rule, however, provides

20 Rec. Doc. 40. 21 Id. at p. 2. 22 Id. 23 Braud v. Transport Service Co. of Illinois, 445 F.3d 801, 806 (5th Cir. 2006). 24 Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

New York Life Insurance v. Brown
84 F.3d 137 (Fifth Circuit, 1996)
Thompson v. Brown
91 F.3d 20 (Fifth Circuit, 1996)
Jacobsen v. Osborne
133 F.3d 315 (Fifth Circuit, 1998)
Rogers v. Hartford Life & Accident Insurance
167 F.3d 933 (Fifth Circuit, 1999)
Lewis v. Lynn
236 F.3d 766 (Fifth Circuit, 2001)
Braud v. Transport Service Co.
445 F.3d 801 (Fifth Circuit, 2006)
Jenkens & Gilchrist v. Groia & Co.
542 F.3d 114 (Fifth Circuit, 2008)
Millan v. USAA General Indemnity Co.
546 F.3d 321 (Fifth Circuit, 2008)
Ray v. Alexandria Mall
434 So. 2d 1083 (Supreme Court of Louisiana, 1983)
Freight Terminals, Inc. v. Ryder System, Inc.
461 F.2d 1046 (Fifth Circuit, 1972)

Cite This Page — Counsel Stack

Bluebook (online)
Deloune v. Mahaffey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deloune-v-mahaffey-lamd-2025.