Kerns v. Smith County

District Court, E.D. Texas·Decided September 22, 2025·No. 6:24-cv-00427·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:24-cv-00427 Matthew J. Kerns, Plaintiff, v. Smith County, Texas, et al., Defendants.

OPINION AND ORDER Plaintiff, proceeding pro se, brought this case against Smith County, two state judges, and several other judicial entities and employees. Doc. 35. The case was referred to a magistrate judge. Doc. 4. Plaintiff alleged numerous claims under 42 U.S.C. §§ 1983, 1985, 1986; the Americans with Disabilities Act (ADA); the Rehabilitation Act (RA); and other state statutes. Doc. 35. De- fendants filed motions to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Docs. 41, 42, 45. The magistrate judge issued a report recommending that all three motions be granted. Doc 53. Plaintiff timely objected to the report. Doc. 62. The court reviews the objected-to portions of a magistrate judge’s report and recommendation de novo. Fed. R. Civ. P. 72(b)(3). However, “the objections must specifically identify those findings objected to. Frivolous, conclusive, or general ob- jections need not be considered by the district court.” /Vettles ». Wainwright, 677 F.2d 404, 410 n.8 (5th Cir. Unit B 1982) (en banc), overruled on other grounds by Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415 (5th Cir. 1996) (en banc). When there are no timely objections, or the objections are improper, “the court need only satisfy itself that there is no clear error on the face of the record.” Fed. R. Civ. P. 72(b), advisory committee’s notes to 1983 addition.

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I. Plaintiff’s objections Objection I Plaintiff’s first objection appears to make a claim against the magistrate judge for discrimination based on plaintiff’s disability. Doc. 62 at 3–4. No such claim is asserted in this action; the mag- istrate judge is not a defendant here. Thus, this objection is with- out merit and overruled. Objection II Next, plaintiff asserts that the report is deficient for failing to consider several alleged “admissions” of defendants. Doc. 62 at 4–5. However, at the pleading stage, the court considers the suf- ficiency of the factual allegations in the complaint. The evidence or admissions that may support a claim are irrelevant to whether the plaintiff has stated a plausible claim to relief. Thus, this objec- tion is overruled. Objection III Plaintiff asserts that the magistrate judge misapplied the doc- trines of sovereign immunity, judicial immunity, and quasi-judi- cial immunity to plaintiff’s ADA claims. Doc. 62 at 5. However, the report did not rely on the doctrines of judicial or quasi-judicial immunity. Furthermore, as explained below, the court agrees with the magistrate judge’s sovereign-immunity conclusion. Even if sovereign immunity did not apply, the ADA claims would still be dismissed for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Thus, this objection is overruled. Objection IV Next, plaintiff objects to the magistrate judge’s recommenda- tion to dismiss his Title V ADA claim “without discussion.” Doc. 62 at 5–6. This objection mischaracterizes the record. The magis- trate judge discussed plaintiff’s Title V claims at length. Doc. 53 at 11, 15–21. The magistrate judge found that (1) plaintiff’s Title V claim could not proceed against defendants in their individual capacities, (2) plaintiff had failed to adequately plead an underly- ing Title II claim upon which to base the Title V claim, and (3) plaintiff did not plead any facts indicating retaliation. As dis- cussed below, the court agrees with those conclusions. Thus, this objection is overruled. Objection V Next, plaintiff objects that the magistrate judge failed to con- sider several allegations raised in his response to Defendant Gun- ter’s motion to dismiss. Doc 62 at 6–7. Plaintiff argues that be- cause the magistrate judge issued the report the day after plaintiff filed his response, the magistrate did not consider that response. Id. at 6. First, plaintiff’s objection is purely speculative. Second, the magistrate did not err in failing to consider these new allega- tions because they were outside the pleadings. “In considering a motion to dismiss for failure to state a claim, a district court must limit itself to the contents of the pleadings, including attachments thereto.” Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498 (5th Cir. 2000). Thus, this objection is overruled. Objection VI Plaintiff also objects that the magistrate judge failed to con- sider plaintiff’s response brief before issuing the report. This as- sertion is based solely on the fact that the magistrate judge issued the report the day after the response brief was filed. This objec- tion is speculative. Thus, the objection is overruled. Objection VII Finally, plaintiff objects that the magistrate judge fabricated unity between defendants to dismiss plaintiff’s conspiracy claim. Doc. 62 at 8. Plaintiff argues that because defendants Delmas and Hahn are county court employees and defendants Gunter and Jackson are state judges, the pairs must be considered separately for purposes of alleging conspiracy. However, the magistrate judge alternatively found that that plaintiff’s claims under 42 U.S.C. §§ 1985 and 1986 should be dismissed for failure to allege a constitutional violation. Doc. 53 at 26–29. Because a constitu- tional violation is a prerequisite to a claim under §§ 1985 and 1986, the court need not consider this objection. II. Unobjected portions of the report As explained above, the court reviews unobjected-to portions of the report only for clear error. Fed. R. Civ. P. 72(b), advisory committee’s notes to 1983 addition. This includes the portions of the report for which the objections are frivolous, conclusive, or general. Having addressed the various insufficiencies in plain- tiff’s objections, the court concludes that there are no proper ob- jections to any other portion of the report. As such, the court re- views the report for clear error and is satisfied that none exists. However, considering plaintiff’s pro se status, the court will ad- dress some of plaintiff’s claims in greater detail. III. ADA claims The magistrate judge construed plaintiff’s pro se complaint to include Title II ADA claims against all defendants in their indi- vidual capacity. Doc. 53 at 5. These claims fail because defendants are not subject to liability in their individual capacities under Title II. Laird v. Spencer, No. 20-30237, 2025 WL 79826, at *2 (5th Cir. Jan. 13, 2025) (“Thus, unlike § 1983, the ADA and section 504 do not permit personal-capacity suits against government offi- cials.”); Pena v. Bexar Cnty., 726 F. Supp. 2d 675, 689–90 (W.D. Tex. 2010) (noting that Title II does not provide for individual liability).

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