Green v. City of Monroe

District Court, W.D. Louisiana·Decided April 7, 2025·No. 3:22-cv-00884·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA MONROE DIVISION

DAVID GREEN ET AL CASE NO. 3:22-CV-00884

VERSUS JUDGE TERRY A. DOUGHTY

CITY OF MONROE ET AL MAG. JUDGE KAYLA D. MCCLUSKY

MEMORANDUM RULING

Before the Court is a Motion for Summary Judgment [Doc. No. 107] filed by Defendant the City of Monroe (“the City”). Plaintiffs David Green, David Ruff, LaDaizya Tillman, Dakedra Jones, Dailour McFee, Ladaveon McFee, and Debra Bailey, on behalf of her minor child, J.B. (collectively, “Green”) filed an Opposition [Doc. No. 120], and the City filed a Reply [Doc. No. 126]. For the reasons stated below, the Motion is GRANTED. I. FACTS AND PROCEDURAL BACKGROUND On one clear-skied sunny day, a man was seen wandering in the middle of a road. Just a few hours later, he tragically wound up dead. In short form, this is what happened. On April 3, 2021, Officer Jonathan Daniel (“Officer Daniel”) of the City of Monroe’s Police Department spotted David Harris (“Harris”) walking in the middle of a street holding up traffic.1 Officer Daniel quickly detained Harris and was advised by a passerby that Harris suffered from mental illness.2 Officer Daniel then drove

1 [Doc. No. 120-2, p.1]. 2 [Id.]. Harris to a hospital for medical care.3 However, Harris refused to get out of the patrol car when they arrived at the hospital.4 Two other police officers, Lawrence Moore and Russell McCall, came to aid Officer Daniel.5 Harris was then forcibly removed from

the vehicle, but continued to resist being put on the hospital stretcher.6 Over the next twelve minutes, Harris was held down to the ground and tasered several times.7 And the only known video footage of the incident came from a camera strapped to Officer Daniel’s uniform. Though hospital staff were present at the scene and witnessed the entire incident, Harris was carried back to the patrol car and transported to Ouachita Correctional Center (“OCC”), where he died shortly after.8 On April 2, 2022, Harris’ family—including David Green—filed suit against

the City, as Officer Daniel’s employer, seeking recovery under Louisiana Civil Code Articles 2315 and 2317.9 In the course of litigation, Green offered the expert opinion of Dr. William Anderson (“Dr. Anderson”), who testified that only a knee placed on the back of a neck with significant force could have caused Harris’ fatal injuries.10 On January 16, 2025, the City filed the pending Motion11 asserting that no genuine issue of material fact exists and that it is entitled to summary judgment as

to the remaining state-law wrongful death and survival claims. Green opposes the

3 [Id.]. 4 [Id.]. 5 [Id.]. 6 [Id.]. 7 [Id.]. 8 [Id., p. 2]. 9 [Doc. Nos, 1, 2]. Green previously sought recovery against the City under other federal and state claims but they were dismissed by this Court. [Doc. Nos. 49, 58]. 10 [Doc. No. 107-9, p. 8]. 11 [Doc. No. 107]. Motion and argues that there is a genuine dispute of material facts as to those claims.12 The issues have been briefed and the Court is prepared to rule.

II. LAW & ANALYSIS A. Standard of Review A court will grant summary judgment “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). If the movant meets their initial burden of showing no genuine issue of material fact, “the burden shifts to the nonmoving party to produce evidence or designate specific facts showing the existence of a genuine

issue for trial.” Distribuidora Mari Jose, S.A. de C.V. v. Transmaritime, Inc., 738 F.3d 703, 706 (5th Cir. 2013) (cleaned up). A fact is “material” when proof of its existence or nonexistence would affect the lawsuit’s outcome under applicable law in the case. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). In other words, “the mere existence of some alleged factual dispute will not defeat an otherwise properly supported motion for summary judgement.” Id. at 247-48. And a dispute about a

material fact is “genuine” only if the evidence is such that a reasonable fact finder could render a verdict for the nonmoving party. Id. While courts will “resolve factual controversies in favor of the nonmoving party,” an actual controversy exists only “when both parties have submitted evidence of contradictory facts.” Little v. Liquid Air. Corp., 37 F.3d 1069, 1075 (5th Cir. 1994).

12 [Doc. No. 120]. But summary judgment is appropriate when the evidence is “merely colorable or is not significantly probative.” Cutting Underwater Tech. USA, Inc. v. Eni U.S. Operating Co., 671 F.3d 512, 517 (5th Cir. 2012) (cleaned up).

Moreover, “a party cannot defeat summary judgment with conclusory allegations, unsubstantiated assertions, or only a scintilla of evidence.” Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337, 343 (5th Cir. 2007) (cleaned up). Courts “may not make credibility determinations or weigh the evidence” and “must resolve all ambiguities and draw all permissible inferences in favor of the non-moving party.” Total E & P USA Inc. v. Kerr–McGee Oil and Gas Corp., 719 F.3d 424, 434 (5th Cir. 2013) (citations omitted).

Finally—and importantly—there can be no genuine dispute as to a material fact when a party “fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof of trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986). B. The State Law Claims & Employer Liability Green’s only remaining claims against the City are state-law wrongful death

and survival claims based on Officer Daniel’s actions.13 These claims stem from Articles 2315.1, 2315.2, and 2316 of Louisiana’s Civil Code.14 Article 2315.1 provides

13 [Doc. No. 2, p. 15-19]; [Doc. No. 49, p. 26, n.8]; [Doc. No. 107-2, p. 14]. 14 Green originally pointed to Article 2317 of the Louisiana Civil Code in his Complaint rather than Article 2316. [Doc. No. 2, 15-18]. Article 2317 states that “[w]e are responsible, not only for the damage occasioned by our own act, but for that which is caused by the act of persons for whom we are answerable, or of the things which we have in our custody. This, however, is to be understood with the following modifications.” However, Green never mentioned Article 2317 in his Opposition to the City’s pending Motion, and he has failed to provide a sufficient basis as to how Article 2317 could in any way support his claims. Instead, Green uses his Opposition to allege that the City may be liable under Article 2316. Green’s survival action, whereas Article 2315.2 sets out Green’s wrongful death claim. La. Civ. Code. 2315.1, 2315.2. And Article 2316 “merely enlarges the provisions of Article 2315 so as to include acts of negligence, imprudence, or want of skill.” Young

v. McCullium, 74 So. 2d 339, 340 (La. App. 1 Cir. 1954). The common thread that traces liability across these three statutes is that the defendant must have caused the offense.

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

Green v. City of Monroe, (W.D. La. 2025).

Green v. City of Monroe (Green v. City of Monroe) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Little v. Liquid Air Corp.
37 F.3d 1069 (Fifth Circuit, 1994)
Turner v. Baylor Richardson Medical Center
476 F.3d 337 (Fifth Circuit, 2007)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Total E & P USA, Inc. v. Kerr-McGee Oil & Gas Corp.
719 F.3d 424 (Fifth Circuit, 2013)
Vicknair v. Hibernia Bldg. Corp.
479 So. 2d 904 (Supreme Court of Louisiana, 1985)
Kyser v. Metro Ambulance, Inc.
764 So. 2d 215 (Louisiana Court of Appeal, 2000)
Baumeister v. Plunkett
673 So. 2d 994 (Supreme Court of Louisiana, 1996)
Young v. McCullium
74 So. 2d 339 (Louisiana Court of Appeal, 1954)
Roberts v. Benoit
605 So. 2d 1032 (Supreme Court of Louisiana, 1992)
Giammanchere v. Ernst
742 So. 2d 572 (Louisiana Court of Appeal, 1999)
Tyralyn Harris v. New Orleans Police Depart
745 F.3d 767 (Fifth Circuit, 2014)