Glenn Alphonso v. State of Louisiana, Through the Louisiana Department of Safety and Corrections, et al.

CourtDistrict Court, M.D. Louisiana
DecidedJanuary 21, 2026
Docket3:25-cv-00605
StatusUnknown

This text of Glenn Alphonso v. State of Louisiana, Through the Louisiana Department of Safety and Corrections, et al. (Glenn Alphonso v. State of Louisiana, Through the Louisiana Department of Safety and Corrections, et al.) 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
Glenn Alphonso v. State of Louisiana, Through the Louisiana Department of Safety and Corrections, et al., (M.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

GLENN ALPHONSO CIVIL ACTION

VERSUS NO. 25-605-BAJ-EWD

STATE OF LOUISIANA, THROUGH THE LOUISIANA DEPARTMENT OF SAFETY AND CORRECTIONS, ET AL.

NOTICE

Please take notice that the attached Magistrate Judge’s Report and Recommendation has been filed with the Clerk of the U.S. District Court.

In accordance with 28 U.S.C. § 636(b)(1), you have 14 days after being served with the attached report to file written objections to the proposed findings of fact, conclusions of law, and recommendations set forth therein. Failure to file written objections to the proposed findings, conclusions and recommendations within 14 days after being served will bar you, except upon grounds of plain error, from attacking on appeal the unobjected-to proposed factual findings and legal conclusions accepted by the District Court.

ABSOLUTELY NO EXTENSION OF TIME SHALL BE GRANTED TO FILE WRITTEN OBJECTIONS TO THE MAGISTRATE JUDGE’S REPORT.

Signed in Baton Rouge, Louisiana, on January 21, 2026. S ERIN WILDER-DOOMES UNITED STATES MAGISTRATE JUDGE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

STATE OF LOUISIANA, THROUGH THE LOUISIANA DEPARTMENT OF SAFETY AND CORRECTIONS, ET AL.

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION

Before the Court is the Motion to Remand (“the Motion”),1 filed by Glenn Alphonso (“Plaintiff”) which is opposed by Louisiana Department of Public Safety and Corrections (“DPSC”) and Captain Brandon Montgomery (“Montgomery”) (collectively “Defendants”).2 Because the record reflects that Montgomery was served and did not timely consent to removal, it is recommended3 that the Motion be granted, remanding this case to the Twentieth Judicial District Court for the Parish of East Feliciana, State of Louisiana. As removal was objectively unreasonable, it is also recommended that Plaintiff be awarded just costs and actual expenses incurred as a result of the removal upon Plaintiff providing additional information. I. BACKGROUND Plaintiff filed his Petition for Damages, asserting claims against Defendants for use of unnecessary and excessive force and retaliation in Louisiana state court on March 3, 2025.4 DPSC removed the case to this Court on July 9, 2025, asserting that the Court has federal subject matter

1 R. Doc. 6 and see R. Doc. 21 (reply memorandum). 2 R. Doc. 12. 3 See, e.g., Davidson v. Georgia-Pacific, L.L.C., 819 F.3d 758, 765 (5th Cir. 2016) (“[A] motion to remand is a dispositive matter on which a magistrate judge should enter a recommendation to the district court subject to de novo review.”). 4 R. Doc. 1-3, p. 1. jurisdiction as Plaintiff asserts that his Eighth Amendment Rights were violated by Montgomery and brings a claim under 42 U.S.C. § 1983 for that violation.5 The Notice of Removal also states that Montgomery had not been served when the case was removed.6 On July 14, 2025, Plaintiff filed a Motion to Remand, asserting that Montgomery was properly served on June 9, 2025, and that DPSC failed to obtain unanimous consent to removal,

requiring remand of the case as removal was procedurally defective.7 Additionally, Plaintiff contends that removal was improper because there was no original subject matter jurisdiction over any claim pleaded in this case against the removing defendant, DPSC.8 Finally, Plaintiff asks the Court to award just costs and actual expenses, including attorney’s fees incurred as a result of the improper removal.9 Montgomery answered Plaintiff’s Petition on July 22, 2025.10 On August 4, 2025, Defendants filed their opposition to the Motion, asserting that service on Montgomery was defective because DPSC’s Legal Headquarters only received a service citation directed to DPSC, not to Montgomery.11 Defendants further argue that the Court has original jurisdiction over the case, including the claims against DPSC.12

5 R. Doc. 1, ¶ 1, citing R. Doc. 1-3, p. 5, ¶¶ 21-23. 6 R. Doc. 1, ¶ 3. 7 R. Doc. 6-2, p. 1. 8 Id. at pp. 1, 2-3. 9 Id. at p. 3. 10 R. Doc. 8. 11 R. Doc. 12, pp. 1-2, 4. 12 Id. at pp. 2-3. In reply, Plaintiff asserts that Defendants’ opposition admits that Montgomery was served through his agent for service of process, Rhonda Weldon, and, therefore, there is no doubt that the Notice of Removal was filed without the consent of all defendants.13 II. LAW AND ANALYSIS A. Applicable Legal Standards

“When a civil action is removed solely under [28 U.S.C.] section 1441(a), all defendants who have been properly joined and served must join in or consent to the removal of the action.”14 According to the Fifth Circuit, the “rule of unanimity” requires that each served defendant join in the notice of removal or that there be a “timely filed written indication from each served defendant…that it has actually consented to such action.”15 “If defendants are served at different times, and a later-served defendant files a notice of removal, any earlier-served defendant may consent to the removal even though that earlier-served defendant did not previously initiate or consent to removal.”16 “Formal service is also required to trigger a defendant’s obligation to join in or consent to removal.”17

The Fifth Circuit has explained that while only consent to removal is required, “a defendant must do so itself.”18 Accordingly, to demonstrate a defendant’s consent to removal requires “some timely filed written indication from each served defendant, or from some person or entity purporting to formally act on its behalf in this respect and to have authority to do so, that it has

13 R. Doc. 21. 14 28 U.S.C. § 1446(b)(2)(A); see also Baxter v. Anderson, No. 16-142, 2016 WL 3748720, at *3 (M.D. La. June 21, 2016). 15 Getty Oil Corp. v. Ins. Co. of N. Am., 841 F.2d 1254, 1262, n.11 (5th Cir. 1988). 16 28 U.S.C. § 1446(b)(2)(C). 17 Coleman v. Burlington Ins. Co., No. 24-512, 2024 WL 3843029, at *2 (W.D. La. July 3, 2024), report and recommendation adopted, No. 24-512, 2024 WL 4369729 (W.D. La. Oct. 1, 2024), citing T.E. Const. Specialties, Inc. v. Vista Benefits, Inc., No. 03-184, 2003 WL 22259075 (W.D. Tex. 2003). 18 Getty Oil, 841 F.2d at 1262, n.11. actually consented to such action. Otherwise, there would be nothing on the record to ‘bind’ the allegedly consenting defendant.”19 As explained by this Court, “various district court decisions in the Fifth Circuit applying Getty Oil have consistently rejected representations from one party that the other parties consent in the removal and have therefore granted a motion to remand.”20 Finally, properly served and joined defendants must join in the removal within the thirty-day period in

which the removal itself must be filed.21 Failure to join all defendants in the removal is a procedural defect that cannot be remedied after the thirty-day removal period.22 But there are exceptions to the rule of unanimity.

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Glenn Alphonso v. State of Louisiana, Through the Louisiana Department of Safety and Corrections, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/glenn-alphonso-v-state-of-louisiana-through-the-louisiana-department-of-lamd-2026.