Ladarion Hughes, et al. v. Smith County, Texas

CourtDistrict Court, E.D. Texas
DecidedNovember 18, 2025
Docket6:23-cv-00344
StatusUnknown

This text of Ladarion Hughes, et al. v. Smith County, Texas (Ladarion Hughes, et al. v. Smith County, Texas) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ladarion Hughes, et al. v. Smith County, Texas, (E.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

LADARION HUGHES, et al., § § Plaintiffs, § § v. § Case No. 6:23-cv-344-JDK § SMITH COUNTY, TEXAS, § § Defendant. §

MEMORANDUM OPINION AND ORDER Before the Court is Plaintiffs’ unopposed motion for preliminary approval of a proposed class action settlement. Docket No. 64. Plaintiffs filed this action alleging that Defendant Smith County, Texas, violated their Fourteenth Amendment rights for failing to timely release them from imprisonment. After consenting to mediation, the parties engaged in several negotiations and two formal settlement conferences with Magistrate Judge K. Nicole Mitchell. Docket No. 64 at 4. On April 5, 2025, the parties reached a global settlement. Id. Plaintiffs now ask the Court to preliminarily approve the settlement and conditionally certify a settlement class. As explained below, the Court GRANTS the motion. I. BACKGROUND This is a civil rights case. Named Plaintiffs Ladarion Hughes, Angela Alonzo, and Demarcus Lively filed this class action lawsuit against Smith County on July 11, 2023, alleging that the County violated the Fourteenth Amendment by failing to release them and similarly situated individuals (“Class Members”) within a reasonable period of time after they had completed their felony criminal sentences. Docket No. 1 at 20. Though the Plaintiffs were allegedly over-detained for different periods of time, all similarly claim that they were wrongfully incarcerated due to the County’s “unlawful policies and practices.” Id. at 12–16.

After Plaintiffs filed their motion for preliminary approval of the proposed class action settlement, the parties filed a notice of settlement. Docket No. 65. The parties stipulate to the certification of the class as follows: “All individuals who were detained at the Smith County Jail between July 11, 2021, and December 31, 2024, and who (1) were convicted of a felony offense; (2) completed their custodial felony sentence at the Smith County Jail; and (3) were not released within two days following the completion of their custodial felony sentence.” Docket. No. 64 at 7. In

exchange for $1,500,000, the Named Plaintiffs and proposed Class Members have agreed to “fully and finally acquit, relinquish, and discharge” all claims that relate to or arise out of the allegations set forth in the complaint. Id. at 6. A total of $1,000,000 will be distributed to Class Members in proportion to the number of compensable detention days. Id. The remainder of the fund will be allocated to pay attorneys’ fees, costs, and expenses; class administration costs; and a service award to the Named

Plaintiffs. Id. Plaintiffs’ motion for preliminary approval of the proposed class action settlement asks the Court to (1) grant preliminary approval of the proposed $1,500,000 non-reversionary settlement; (2) conditionally certify the Settlement Class; (3) appoint Akeeb Dami Animashaun; Camilla Hsu and Nathan Fennell (Deason Criminal Justice Reform Center); and Margaret Gould and Jon Loevy (Loevy & Loevy) as Class Counsel; (4) appoint American Legal Claims Services, Inc. to serve as the Settlement Administrator; (5) direct notice to be disseminated to Class Members in the form and manner proposed by the parties; and (6) set the deadlines

for class notice, exclusion and objection deadlines, and a hearing date and schedule for final approval of the settlement and consideration of Class Counsel’s fee application, as set forth in a proposed, agreed-upon schedule. Docket No. 64. Defendant does not oppose the motion. See Docket No. 64-1 at 6. II. ANALYSIS Federal Rule of Civil Procedure 23(e) governs class settlements. Under Rule 23(e), a class action “may be settled, voluntarily dismissed, or compromised only with

the court’s approval.” To approve a class settlement, the Court must first determine whether a class should be preliminarily certified for settlement purposes. Kostka v. Dickey’s Barbecue Restaurants, Inc., No. 3:20-CV-03424-K, 2022 WL 16821685, at *2 (N.D. Tex. Oct. 14, 2022), report and recommendation adopted, No. 3:20-CV-03424-K, 2022 WL 16821665 (N.D. Tex. Nov. 8, 2022) (citing Bridges v. Ridge Nat. Res., LLC, 2020 WL 7495252, at *2 (W.D. Tex. Jan. 3, 2020)). In making this determination, the

Court must consider the four prerequisites of Rule 23(a) and additional requirements under Rule 23(b). Id. If the Court preliminarily certifies the class, it must then make a preliminary fairness evaluation of the proposed terms of settlement submitted by counsel. McNamara v. Bre-X Mins. Ltd., 214 F.R.D. 424, 426 (E.D. Tex. 2002). If the Court determines that the settlement is fair, the Court will direct that notice of a formal fairness hearing pursuant to Rule 23(e) be given to the class members, at which hearing arguments and evidence may be presented in support of and in opposition to the settlement. Id.

A. Article III Standing Before considering whether to certify a proposed class, the Court must first consider whether the proposed class representatives have Article III standing. Flecha v. Medicredit, Inc., 946 F.3d 762, 769 (5th Cir. 2020); Kostka, 2022 WL 16821685, *3. To establish standing, the Named Plaintiffs must demonstrate that they have suffered an injury in fact that is fairly traceable to Defendant’s conduct and that the injury will likely be redressed by a favorable decision. See Lujan v. Defs. of Wildlife,

504 U.S. 555, 560 (1992). Here, the Named Plaintiffs allege that they were injured by being wrongfully detained after completing their criminal sentences as a result of Smith County’s “unlawful practices and policies.” Docket No. 1. at 12–16. They further allege that a damage award will redress their claimed injury. Docket No. 1 at ¶¶ 106–113. The Court finds that these allegations satisfy the requirements of Article III standing. See Humphrey v. LeBlanc, No. CV 20-233-JWD-SDJ, 2025 WL

2694604, at *37 (M.D. La. Sept. 22, 2025). While the Supreme Court has not yet settled the standard for evaluating standing prior to class certification, the Fifth Circuit has recognized that “it is sufficient for standing purposes that [] plaintiffs seek recovery for an economic harm that they allege they have suffered because for each class member the court must assume arguendo the merits of his or her legal claim at the Rule 23 stage.” In re Deepwater Horizon, 739 F.3d 790, 804 (5th Cir. 2014) (internal quotations omitted) (emphasis in original). When absent class members are “linked” under Rule 23 to the common complaint, “the possibility that some may fail to prevail on their individual

claims will not defeat class membership.” Id. Here, as noted above, the proposed Settlement Class consists of “all individuals who were detained at the Smith County Jail between July 11, 2021, and December 31, 2024, and who (1) were convicted of a felony offense; (2) completed their custodial felony sentence at the Smith County Jail; and (3) were not released within two days following the completion of their custodial felony sentence.” Docket No. 64 at 9. Although the Court is not required to address Article III standing of putative class members at this stage, the Court notes that the

Named Plaintiffs have properly made this allegation for all potential Class Members. B.

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

Related

Lightbourn v. County of El Paso
118 F.3d 421 (Fifth Circuit, 1997)
Mullen v. Treasure Chest Casino, LLC
186 F.3d 620 (Fifth Circuit, 1999)
Stirman v. Exxon Corporation
280 F.3d 554 (Fifth Circuit, 2002)
General Telephone Co. of Southwest v. Falcon
457 U.S. 147 (Supreme Court, 1982)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Amchem Products, Inc. v. Windsor
521 U.S. 591 (Supreme Court, 1997)
Wal-Mart Stores, Inc. v. Dukes
131 S. Ct. 2541 (Supreme Court, 2011)
Union Asset Management Holding A.G. v. Dell, Inc.
669 F.3d 632 (Fifth Circuit, 2012)
In Re: Deepwater Horizon
739 F.3d 790 (Fifth Circuit, 2014)
Steve Simms v. Jerral Jones
836 F.3d 516 (Fifth Circuit, 2016)
Nina Flecha v. Medicredit, Incorporated
946 F.3d 762 (Fifth Circuit, 2020)
Berger v. Compaq Computer Corp.
257 F.3d 475 (Fifth Circuit, 2001)
McNamara v. Bre-X Minerals Ltd.
214 F.R.D. 424 (E.D. Texas, 2002)
Cotton v. Hinton
559 F.2d 1326 (Fifth Circuit, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
Ladarion Hughes, et al. v. Smith County, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ladarion-hughes-et-al-v-smith-county-texas-txed-2025.