Demario Sumlar v. Prentiss County, Mississippi, et al.

CourtDistrict Court, N.D. Mississippi
DecidedJanuary 6, 2026
Docket1:24-cv-00223
StatusUnknown

This text of Demario Sumlar v. Prentiss County, Mississippi, et al. (Demario Sumlar v. Prentiss County, Mississippi, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Demario Sumlar v. Prentiss County, Mississippi, et al., (N.D. Miss. 2026).

Opinion

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

DEMARIO SUMLAR PLAINTIFF

v. CIVIL ACTION NO. 1:24-CV-223-SA-DAS

PRENTISS COUNTY, MISSISSIPPI, et al. DEFENDANTS

ORDER AND MEMORANDUM OPINION On November 23, 2024, Demario Sumlar initiated this lawsuit by filing his Complaint [2] against Prentiss County, Sheriff Randy Tolar, Prentiss County Sheriff Department, Mississippi Department of Public Safety (“MDPS”), Deputy John Doe 1, Deputy John Doe 2, Patrolman John Doe 1, and John and Jane Does 3-10 (collectively referred to as “Defendant Officers”). There are multiple pending Motions [6, 14, 16], wherein the Defendants seek dismissal of the claims asserted against them. The Court, having considered the filings and the applicable authorities, is prepared to rule. Relevant Factual and Procedural Background On November 18, 2023, at approximately 10:30 P.M., Demario Sumlar was stopped at a traffic safety checkpoint near Booneville, Mississippi. An officer claimed that, upon initial contact, he noticed a bottle of liquor in the driver side door and the odor of marijuana.1 The officer then directed Sumlar to pull onto the shoulder of the road.2

1 The Complaint [2] does not name any officer and instead refers to them generally as “Defendant Officers.” See [2] at p. 2. Though the Complaint [2] states that the identities of the officers involved in the subject checkpoint were unknown at the time the Complaint [2] was filed, to-date Sumlar has not amended his Complaint [2] to identify the officers, despite the fact that the Defendants identified the officers in their Answer. [4], Ex. 1. According to the Complaint [2], based upon belief the unidentified officers work for the Mississippi Department of Public Safety and the Prentiss County Sheriff’s Department. 2 The Court has reviewed and considered body cam footage from two members of law enforcement present at the traffic safety checkpoint. See [4], Ex. 3-4. The Court notes that the footage does not show the entirety of the events contained in the Complaint [2]. Once Sumlar pulled over, the officer commanded him to exit the vehicle. After conducting a weapons pat down, the officer directed Sumlar to stand at the rear of the car and put his hands on the trunk while he searched the vehicle. During the search, the officer found a small bag of marijuana tucked beneath the driver’s seat.

The officer then walked behind Sumlar, directed him to put his hands behind his back, and informed him that “[he] was going in cuffs.” [4], Ex. 3 at 2:26-2:28. Sumlar initially allowed the officer to handcuff his left wrist before pulling his right arm away and positioning it in front of his body. The officer again attempted to grab Sumlar’s right arm, and after being unable to do so, initiated a takedown. While on the ground, Sumlar positioned his arms in front of himself as the officer attempted to secure his arms. A few seconds after the takedown, two additional officers who were working the checkpoint ran over to help restrain Sumlar and, in the process of assisting with the arrest, one officer placed a knee on the back Sumlar’s neck. The officer removed his knee after Sumlar was handcuffed. Following the arrest, Sumlar was transported to Baptist Memorial Hospital and received treatment for a cut on his forehead that he sustained during the arrest.

Sumlar now brings claims against Prentiss County, the Prentiss County Sheriff’s Department, the Mississippi Department of Public Safety, Sheriff Randy Tolar, in his official capacity, and various John Does in their official and individual capacities. The named Defendants seek dismissal of all claims. Analysis and Discussion As previously noted, Sumlar has asserted a variety of claims against multiple parties, including purported violations of his First and Fourth Amendment rights. The Court will address each defendant separately beginning with MDPS and its Motion to Dismiss [6] and then turning to the remaining Defendants that seek summary judgment via separate Motions [14, 16].3 I. Motion to Dismiss [6] MDPS brings a Motion to Dismiss [6] claiming it is entitled to sovereign immunity and

that this Court therefore lacks subject matter jurisdiction over the claims asserted against it. a. Legal Standard A motion under Federal Rule of Civil Procedure 12(b)(1) asserts a lack of subject matter jurisdiction. In evaluating a Rule 12(b)(1) motion, a court may consider the complaint alone, undisputed facts in the record, and the court’s resolution of disputed facts. Morris v. Thompson, 852 F.3d 416, 419 (5th Cir. 2017) (citing Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2001)). The allegations in the complaint are taken as true in determining whether a sufficient basis for jurisdiction exists. Menchaca v. Chrysler Credit Corp., 613 F.2d 507, 511 (5th Cir. 1980). The burden of establishing jurisdiction rests on the party asserting its existence. Morris, 852 F.3d at 419 (citing Ramming, 281 F.3d at 161). If subject matter jurisdiction is lacking, the case must be

dismissed. Wolcott v. Sebelius, 635 F.3d 757, 762 (5th Cir. 2011). b. Application MDPS contends it is an arm of the state and entitled to sovereign immunity under the Eleventh Amendment. The Eleventh Amendment provides: The judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.

3 The Court feels compelled to note that, although it must view the evidence in the light most favorable to Sumlar at this stage in the proceedings, Sumlar’s failure to respond to the two Motions for Summary Judgment [14, 16], in addition to his failure to otherwise meaningfully participate in this litigation (as explained more fully hereinafter), has undoubtedly made the Court’s task in this regard more difficult. U.S. Const. amend. XI. Although the Eleventh Amendment’s language does not address suits against a State by its own citizens, the Supreme Court has “consistently held that an unconsenting State is immune from suits brought in federal courts by [its] own citizens as well as citizens of another State.” Edelman

v. Jordan, 415 U.S. 651, 662-63, 94 S. Ct. 1347, 39 L. Ed. 2d 662 (1974). The Eleventh Amendment acts to bar an individual “from suing a state in federal court unless the state consents to suit or Congress has clearly abrogated the state’s sovereign immunity.” Perez v. Region 20 Educ. Serv. Ctr., 307 F.3d 318, 326 (5th Cir. 2002). The Eleventh Amendment bars both federal and state law claims against a state in federal court. Yul Chu v. Miss. State Univ., 901 F. Supp. 2d 761, 771 (N.D. Miss. 2012) (citing Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89, 119-21, 104 S. Ct. 900, 79 L. Ed. 2d 67 (1984)) (emphasis added); Kirk v. Miss. Dep’t of Pub. Safety, 2016 WL 10293382, at *4 (S.D. Miss. May 26, 2016) (“[T]he immunity provided by the Eleventh Amendment applies to both federal and state law claims.”). Importantly, sovereign immunity “protects not only states from suit in federal court, but

also ‘arms of the state.’” U.S. Oil Recovery Site Potential Responsible Parties Group v. R.R. Comm’n of Tex., 898 F.3d 497, 501 (5th Cir. 2018) (quoting Richards v. S. Univ., 118 F.3d 450, 452-54 (5th Cir. 1997)).

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Demario Sumlar v. Prentiss County, Mississippi, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/demario-sumlar-v-prentiss-county-mississippi-et-al-msnd-2026.