Doe v. Burlew

District Court, W.D. Kentucky·Decided July 18, 2024·No. 4:24-cv-00045·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY OWENSBORO DIVISION CIVIL ACTION NO. 4:24-CV-00045-GNS

JOE DOE, on behalf of himself and others similarly situated PLAINTIFF

v.

JOHN BURLEW, in his official capacity as Daviess County Attorney, and on behalf of all County Attorneys in their official capacities DEFENDANT

MEMORANDUM OPINION AND ORDER This matter is before the Court on Plaintiff’s Motion for Class Certification (DN 13). The motion is ripe for adjudication. For the reasons stated below, the motion is DENIED. I. BACKGROUND During 2024 legislative session, the Kentucky General Assembly passed and Governor Andy Beshear signed into law Senate Bill 249. See S.B. 249, 2024 Ky. Gen. Assemb., Reg. Sess. (codified as KRS 17.544). This law requires persons on the Kentucky Sex Offender Registry who committed a criminal offense against a minor to use their full legal name on social media platforms. See KRS 17.544. Plaintiff John Doe (“Doe”) filed this action on his own behalf and on behalf of others similarly situated against Defendant John Burlew (“Burlew”), in his official capacity as Daviess County Attorney and on behalf of all County Attorneys in their official capacities. (Am. Compl. ¶ 5, DN 11). Doe asserts two claims under 42 U.S.C. § 1983 for violations of his constitutional rights under the First Amendment. (Am. Compl. ¶¶ 53-67). In particular, Doe asserts that the challenged law violates his right to speak anonymously and is unconstitutionally overbroad. (Am. Compl. ¶¶ 53-67). Doe moves for certification of a plaintiff class and a defendant class. (Pl.’s Mot. Class Certification, DN 13). Burlew opposes the motion. (Def.’s Combined Resp. Pl.’s Mots. & Cross- Mot. Summ. J., DN 19).

II. JURISDICTION This Court has jurisdiction because a federal question is presented. See 28 U.S.C. § 1331. III. STANDARD OF REVIEW “While the district court has broad discretion in certifying class actions, it must exercise that discretion within the framework of Rule 23.” Coleman v. Gen. Motors Acceptance Corp., 296 F.3d 443, 446 (6th Cir. 2002) (citing Cross v. Nat’l Tr. Life Ins. Co., 553 F.2d 1026, 1029 (6th Cir. 1977)). As the moving party, Doe bears the burden of proof to establish that certification is proper. See In re Am. Med. Sys., Inc., 75 F.3d 1069, 1079 (6th Cir. 1996) (6th Cir. 1996) (citing Gen. Tel. Co. of the Sw. v. Falcon, 457 U.S. 147, 161 (1982); Senter v. Gen. Motors Corp., 532 F.2d 511,

522 (6th Cir. 1976)). Fed. R. Civ. P. 23(a) dictates requirements of numerosity, commonality, typicality, and adequacy for all class action lawsuits, and a court must conduct “a rigorous analysis[] that the prerequisites of Rule 23(a) have been satisfied.” Fed. R. Civ. P. 23(a); Falcon, 457 U.S. at 161. If all of these requirements are not satisfied, certification must be denied. See Ball v. Union Carbide Corp., 385 F.3d 713, 727 (6th Cir. 2004) (citing Sprague v. Gen. Motors Corp., 133 F.3d 388, 397 (6th Cir. 1998) (en banc)). Because the merits of the underlying claims are not considered in determining whether to certify a class, a court instead assumes that the complaint’s substantive allegations are true and that the pleading states cognizable claims. See Eisen v. Carlisle & Jacquelin, 417 U.S. 156, 178 (1974) (“In determining the propriety of a class action, the question is not whether the plaintiff or plaintiffs have stated a cause of action or will prevail on the merits, but rather whether the requirements of Rule 23 are met.” (citation omitted)); Little Caesar Enters., Inc. v. Smith, 172 F.R.D. 236, 241 (E.D. Mich. 1997) (“A Rule 23 determination is wholly procedural and has nothing to do with whether a plaintiff will ultimately prevail on the substantive merits of its

claims.” (citation omitted)). “Nonetheless, the Court must undertake an analysis of the issues and the nature of required proof at trial to determine whether the matters in dispute and the nature of plaintiffs’ proofs are principally individual in nature or are susceptible of common proof equally applicable to all class members.” Little Caesar Enters., 172 F.R.D. at 241 (citation omitted). “[W]hen a court is in doubt as to whether to certify a class action, it should err in favor of allowing a class.” Id. at 241-42 (citations omitted). IV. DISCUSSION A. Defendant Class The parties’ arguments primarily concern the propriety of a defendant class certification in

this case. (See Pl.’s Mot. Class Certification 8-16; Def.’s Combined Resp. Pl.’s Mots. & Cross- Mot. Summ. J. 5-11; Pl.’s Consolidated Reply & Resp. Def.’s Mot. Summ. J. 2-6, DN 20). Burlew contends that Doe lacks standing to sue every County Attorney in Kentucky. (Def.’s Combined Resp. Pl.’s Mots. & Cross-Mot. Summ. J. 8-10). Doe concedes that because he resides in Daviess County, he has only a claim against Burlew, but Doe asserts that he still may sue every County Attorney based on the judicial link doctrine. (Pl.’s Mot. Class Certification 14-15 (citing La Mar v. H & B Novelty & Loan Co., 489 F.2d 461, 470 (9th Cir. 1973)). To satisfy Article III’s “Cases” or “Controversies” requirement, plaintiffs may only sue when they have standing—that is, when they have suffered a redressable injury that is traceable to each defendant. Fox v. Saginaw Cnty., 67 F.4th 284, 292-93 (6th Cir. 2023) (citations omitted). In the name of efficiency, the judicial link doctrine (or juridical link doctrine) allows “named plaintiffs [to] bring a class action against some defendants who did not injure them if the class members would have standing and if the named plaintiff can meet Rule 23’s requirements.” Id. at 293, 296. In Fox, however, the Sixth Circuit expressly rejected the judicial link doctrine. Id. at

294-96. Fox concerned a Michigan landowner who failed to pay property taxes. Id. at 288. As a result, Gratiot County, Michigan, sold his property, paid his taxes, and kept the surplus, which the plaintiff argued was an unconstitutional taking. Id.

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