John Woodruff v. Luigi Ragazzoni, et al.

CourtDistrict Court, N.D. Alabama
DecidedOctober 16, 2025
Docket2:23-cv-01155
StatusUnknown

This text of John Woodruff v. Luigi Ragazzoni, et al. (John Woodruff v. Luigi Ragazzoni, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Woodruff v. Luigi Ragazzoni, et al., (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

JOHN WOODRUFF, Plaintiff,

v. Case No. 2:23-cv-1155-CLM-NAD

LUIGI RAGAZZONNI, et al., Defendants.

MEMORANDUM OPINION AND ORDER The magistrate judge has entered a report, recommending that under 28 U.S.C. § 1915(e) and 1915A, the court dismiss without prejudice all of Plaintiff John Woodruff’s claims except his Fourth Amendment wrongful search and seizure claims against Defendants Luigi Ragazzoni and David Pressley (Counts I and III). (Doc. 18). The magistrate judge recommended that the court refer these Fourth Amendment claims to him for further proceedings. (See id., p. 21). Woodruff objects to the Report and Recommendation. (See Doc. 20). BACKGROUND 1. Statement of the alleged facts: On August 27, 2021, Woodruff learned that Shelby County had issued a warrant for his arrest based on alleged violations of his probation for failure to register a vehicle in compliance with the Alabama Sex Offender Registration and Community Notification Act. (Doc. 9, p. 2; Doc. 18, p. 4, n.1). That evening, Woodruff drove to his fitness club where Pelham police officers directed him to exit his vehicle. (Doc. 9, p. 3). The Pelham officers handcuffed Woodruff, but they informed him that they only were holding him until Shelby County officers arrived. (Id.). Ragazzoni, a Shelby County deputy, then arrived and took custody of Woodruff. (Id.). Woodruff told Ragazzoni that his “vehicle was not to be towed as it was lawfully parked upon private commercial property.” (Id., p. 4). But Ragazzoni “rifle[d] through [Woodruff’s] truck” and then had it towed. (Id.). Around three days later, Woodruff bonded out of the Shelby County Jail and retrieved his impounded truck. (Id.). That same day, the Shelby County prosecutor moved to revoke Woodruff’s probation on an underlying conviction for violating ASORCNA. (Id., see also Doc. 18, p. 6 n.3). A few weeks later, Woodruff went to Buc-ee’s in Leeds, Alabama (Doc. 9, p. 4). After Woodruff left the store, he returned to his truck, which was then surrounded by Leeds police officers who ordered Woodruff to get out of the truck. (Id., p. 5). The officers told Woodruff that they were arresting him on behalf of “Shelby County,” which had located Woodruff from an image of his truck that was “captured by a plate-reading traffic camera in Moody.” (Id.). Pressley, another Shelby County Sheriff’s Deputy, then arrived and placed Woodruff in his patrol car. (Id.). And again, over Woodruff’s protestation, Pressley searched Woodruff’s truck and then impounded it. (Id.). 2. Procedural history: In his amended complaint (doc. 9), Woodruff brings claims for unlawful search and seizure of his truck under federal law (Counts I and III); claims for unlawful search and seizure under state law (Counts II and IV); a claim for “unlawful surveillance” under federal law (Count V); a claim for “unlawful surveillance” under state law (Count VI); “willful negligence” under state law (Count VII); a general claim for violation of his civil rights under federal law (Coun VIII); and a claim for conspiracy under federal law (Count IX). Woodruff does not challenge his underlying arrests or prosecution. (Doc. 9, pp. 4, 6). DISCUSSION Woodruff does not raise any specific objections to the magistrate judge’s recommendation that the court dismiss Counts II, IV, V, VI, VII, and IX. And the court agrees with the magistrate judge’s recommendation that the court dismiss these counts for failure to state a claim. Counts II, IV, VI, and VII are all state-law claims. Under Alabama law, sheriffs and deputy sheriffs “are entitled to immunity from individual-capacity claims for damages whenever the acts that form the basis of their alleged liability were being performed within the line and scope of their employment.” Ex parte Underwood, --- So. 3d ----, 2025 WL 1776225, at *4 (Ala. June 27, 2025) (cleaned up). Because Defendants’ alleged conduct was within the scope of their employment as the Shelby County Sheriff and deputies, they are immune from suit for state-law individual-capacity damages claims. And as the magistrate judge noted, even if the court were to liberally construe Count VII as a § 1983 claim against Sheriff Samaniego, that claim would fail because Woodruff does not plausibly allege a claim of supervisory liability. Plus, Woodruff’s unlawful surveillance claims against Sheriff Samaniego (Counts V and VI) are based only on speculation that Sheriff Samaniego may have used his former employment with DHS to improperly surveil Woodruff. Thus, those counts do not plausibly state a claim for relief. As for Count IX, the magistrate judge correctly noted that the intracorporate conspiracy doctrine bars Woodruff’s § 1983 conspiracy claim. See Grider v. City of Auburn, 618 F.3d 1240, 1260–61 (11th Cir. 2010). The court will thus accept the magistrate judge’s recommendation that the court dismiss these counts and will discuss them no further. A. Judicial Economy Woodruff first asserts that because the magistrate judge recommends that Counts I and III proceed past the screening stage, judicial economy supports allowing all of his claims to proceed. (See Doc. 20, pp. 2–3). According to Woodruff, discovery on his unlawful search and seizure claims will “produce evidence which [will] revive other claims but [will] then require motions to restore claims and motions for discovery in the restored claim, all of which injects avoidable delays.” (Id., p. 3). As explained, most of the claims that the magistrate judge recommends the court dismiss fail as a matter of law. And Woodruff’s unlawful surveillance claims against Sheriff Samaniego are based on pure speculation. The court thus declines to reject the Report and Recommendation based on Woodruff’s belief that discovery might provide him with facts that could revive his deficiently pleaded claims. B. Prison Litigation Reform Act, 28 U.S.C. § 1915A Woodruff next argues that the magistrate judge’s screening of his complaint under the Prison Litigation Reform Act is “overbroad and abusive,” asserting that the Report and Recommendation is “a 23-page dissection of Woodruff’s stated causes of action” rather than “a very limited screening.” (Id.). Woodruff misunderstands the screening provisions of the PLRA. Under the PLRA, this court is required to screen any “civil action in which a prisoner seeks redress from a governmental entity or officer or employee.” 28 U.S.C. § 1915A(a).1 “On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint . . . (1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b)(1)-(2). “And a complaint may be subject to dismissal for failure to state a claim—based on an affirmative defense—. . . when the affirmative defense appears on the face of the complaint.” Wells v. Brown, 58 F.4th 1347, 1350 (11th Cir. 2023). So while Woodruff objects to the magistrate judge’s identification of “defenses which Defendants would propound,” (doc. 20, p. 4), that is the exact role the screening process requires. See, e.g., Bingham v. Thomas, 654 F.3d 1171, 1175 (11th Cir.

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John Woodruff v. Luigi Ragazzoni, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-woodruff-v-luigi-ragazzoni-et-al-alnd-2025.