Genny Jones v. Loudon County, Tennessee and Officer Does 1–5

CourtDistrict Court, E.D. Tennessee
DecidedOctober 22, 2025
Docket3:23-cv-00415
StatusUnknown

This text of Genny Jones v. Loudon County, Tennessee and Officer Does 1–5 (Genny Jones v. Loudon County, Tennessee and Officer Does 1–5) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Genny Jones v. Loudon County, Tennessee and Officer Does 1–5, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

GENNY JONES, ) ) Case No. 3:23-cv-415 Plaintiff, ) ) Judge Atchley v. ) ) Magistrate Judge Poplin LOUDON COUNTY, TENNESSEE and ) OFFICER DOES 1–5, ) ) Defendants. )

MEMORANDUM & ORDER Plaintiff, proceeding through counsel, seeks relief under 42 U.S.C. § 1983 based on events that led to her giving birth in the back of an ambulance on November 20, 2022, the same day she was processed into the Loudon County Jail [Doc. 55]. Now before the Court is Defendant Loudon County’s Motion for Summary Judgment [Doc. 36], in support of which it filed exhibits [Docs. 36-1–27, 40–44] and a memorandum [Doc. 38]. Plaintiff filed a response in opposition to this motion [Doc. 48], in support of which she filed exhibits [Docs. 49-1–25]. Defendant Loudon County filed a reply [Doc. 52]. Also, after Defendant Loudon County filed its Motion for Summary Judgment, Plaintiff filed an amended complaint [Doc. 55] and a Motion in Limine [Doc. 50]. For the reasons set forth below, the Court finds that no genuine issue of material fact remains herein, and Defendant Loudon County is entitled to summary judgment. Accordingly, this Defendant’s Motion for Summary Judgment [Doc. 36] will be GRANTED, Plaintiff’s Motion in Limine [Doc. 50] will be DENIED as moot, and this action will be DISMISSED. I. OFFICER DOES As the Court noted in its previous order, while Plaintiff attempted to amend her complaint to name the Doe Defendants [Doc. 23], she only did so after the applicable statute of limitations had run [Doc. 54 at 3–4]. But Plaintiff’s failure to timely amend her complaint to name the Doe Defendants is fatal to her claims against these Defendants. Smith v. City of Akron, 476 F. App’x

67, 69 (6th Cir. 2012) (holding that adding new, previously unknown Defendants in the place of Doe defendants is not equivalent to substituting parties, but rather amounts to addition of parties, and that Rule 15(c) offers no remedy to a plaintiff seeking to do so after the statute of limitations has passed); Cox v. Treadway, 75 F.3d 230, 240 (6th Cir. 1996) (finding that “Sixth Circuit precedent clearly holds that new parties may not be added after the statute of limitations has run, and that such amendments do not satisfy the ‘mistaken identity’ requirement of Rule 15(c)[]”). Accordingly, the Court sua sponte dismisses Plaintiff’s claims against the Doe Defendants. II. AMENDED COMPLAINT After Defendant Loudon County filed its summary judgment motion, Plaintiff filed an

amended complaint [Doc. 54 at 1–4, 6; Doc. 55]. While neither party has raised the issue of whether the amended complaint affects the summary judgment motion, the Court already noted that the amended complaint only adds facts that have little if any relevance to the municipal liability claims [Doc. 54 at 1–4], which are the only claims remaining herein. As such, the Court finds that it may still rule on the motion for summary judgment. TERA II, LLC v. Rice Drilling D, LLC, 679 F. Supp. 3d 620, 636 (S.D. Ohio 2023) (noting that “subsequent filings of amended complaints do not necessarily moot prior motions for summary judgment where the claims remained substantively the same . . . .”) (collecting cases) (citations omitted).

2 III. SUMMARY JUDGMENT A. Standard Summary judgment is proper when the pleadings and evidence, viewed in a light most favorable to the nonmoving party, illustrate that no genuine issue of material fact exists, and the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a), (c); Celotex Corp. v.

Catrett, 477 U.S. 317, 322–23 (1986). A fact is deemed “material” if resolving that fact in favor of one party “might affect the outcome of the suit under governing law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To establish an entitlement to summary judgment, the moving party must demonstrate that the nonmoving party cannot establish an essential element of their case for which they bear the ultimate burden of proof at trial. Celotex, 477 U.S. at 322; Moore v. Philip Morris Cos., Inc., 8 F.3d 335, 339 (6th Cir. 1993). Once the motion is properly supported with competent evidence, the nonmovant must show that summary judgment is inappropriate by setting forth specific facts showing there is a genuine issue for trial. Celotex, 477 U.S. at 323; Anderson, 477 U.S. at 249. The plaintiff cannot meet this

burden with “some metaphysical doubt as to the material facts,” Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986), “conclusory allegations,” Lujan v. Nat’l Wildlife Fed’n., 497 U.S. 871, 888 (1990), or by a mere “scintilla” of evidence, Anderson, 477 U.S. at 252. If the “evidence is such that a reasonable jury could return a verdict for the nonmoving party,” then there is a genuine dispute as to a material fact. Anderson, 477 U.S. at 248. If no proof is presented, however, the Court does not presume that the nonmovant “could or would prove the necessary facts.” Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (citing Lujan, 497 U.S. at 889).

3 B. Background The majority of Plaintiff’s amended complaint and the parties’ summary judgment filings focus on the Loudon County Jail employees’ acts and omissions during Plaintiff’s relevant confinement that ultimately led to Plaintiff giving birth to a baby in the back of an ambulance on the same day she was admitted into the Loudon County Jail, as well as Plaintiff’s own acts and

omissions during her pregnancy and confinement.1 However, as set forth above, the only claims remaining herein are Plaintiff’s municipal liability claims against Defendant Loudon County. And while the Court recognizes that “[t]here can be no liability under Monell without an underlying constitutional violation,” Chambers v. Sanders, 63 F.4th 1092, 1101–02 (6th Cir. 2023) (quoting Robertson v. Lucas, 753 F.3d 606, 622 (6th Cir. 2014)), for purposes of efficiency and simplicity, the Court declines to determine whether any employee of Defendant Loudon County violated Plaintiff’s constitutional rights during the relevant events of November 20, 2022. Instead, the Court will focus only on whether Defendant Loudon County may be liable for any violation of Plaintiff’s constitutional rights.

In her response in opposition to Defendant Loudon County’s Motion for Summary Judgment, Plaintiff specifies that she only seeks relief under § 1983 from Defendant Loudon County based on “[(1)] a failure to train allegation, both as one stemming from a single incident and from a pattern of constitutional violations including denial of post-partum care, as well as [(2)] a theory of inaction when it ignored [Plaintiff] while she was in active labor, in part due to the deputies’ bias against Ms. Jones and [] the existence of a custom of tolerance or acquiescence of

1 The Court recognizes that this is likely because at the time Defendant Loudon County filed its motion for summary judgment, Plaintiff’s motion to amend her complaint to name the Doe Defendants [Doc.

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Bluebook (online)
Genny Jones v. Loudon County, Tennessee and Officer Does 1–5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/genny-jones-v-loudon-county-tennessee-and-officer-does-15-tned-2025.