Leet v. Cotone

CourtDistrict Court, W.D. Louisiana
DecidedMarch 11, 2025
Docket6:24-cv-00586
StatusUnknown

This text of Leet v. Cotone (Leet v. Cotone) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leet v. Cotone, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

HEATH LEET CASE NO. 6:24-CV-00586

VERSUS JUDGE DAVID C. JOSEPH

TIM COTONE ET AL MAGISTRATE JUDGE DAVID J. AYO

REPORT AND RECOMMENDATION

Before this Court are three motions filed by defendants in the above-captioned civil rights suit: (1) MOTION TO DISMISS filed by defendants Sheriff Thomas Romero (“Sheriff Romero”) and the Iberia Parish Sheriff Department (“IPSD”) (Rec. Doc. 4); (2) MOTION TO DISMISS filed by defendant Government of Iberia Parish (“IPG”) (Rec. Doc. 10); and (3) MOTION TO DISMISS filed by defendant Tim Cotone (“Deputy Cotone”) (Rec. Doc. 19). Plaintiff Heath Leet opposes these motions.1 The undersigned issues the following report and recommendation pursuant to 28 U.S.C. § 636. Considering the evidence, law, and argument, and for the reasons explained below, this Court recommends that the MOTION TO DISMISS filed by Sheriff Romero and the IPSD (Rec. Doc. 4) be GRANTED in part and DENIED in part; that the MOTION TO DISMISS filed by the IPG (Rec. Doc. 10) be GRANTED

1 Opposition to Motion to Dismiss by Sheriff Romero and IPSD (Rec. Doc. 4) at Rec. Doc. 8; Reply by Sheriff Romero and IPSD at Rec. Doc. 9; Opposition to Motion to Dismiss by IPG (Rec. Doc. 10) at Rec. Doc. 13); Reply brief by IPG at Rec. Doc. 14; Opposition to Deputy Cotone’s Motion to Dismiss (Rec. Doc. 19) at Rec. Doc. 21. No reply brief was filed by Deputy Cotone to the opposition to his Motion Dismiss. in part and DENIED in part; and that the MOTION TO DISMISS filed by Deputy Cotone (Rec. Doc. 19) be GRANTED in part and DENIED in part. Factual Background Leet was arrested on May 9, 2019 by the IPSD on charges of Accessory After the Fact to Second-Degree Murder in violation of La. R.S. §§ 14:25 and 30.1, and Obstruction of Justice in violation of La. R.S. § 14:130.1(A)(1). Leet’s arrest stemmed from the death of Jessica Morgan (“Morgan”) from a drug overdose on or about December 16, 2018 at a mobile home

Leet shared with Chad Viator (“Viator”) and Taylor Maturin (“Maturin”). (Rec. Doc. 1 at p. 1).2 On December 18, 2018, Leet learned that Morgan was not sick and resting in another room as he was told but was actually dead. Upon learning of Morgan’s death, Leet called 9- 1-1, after which IPSD investigators, including Deputy Kaila Chipman (“Deputy Chipman”), arrived at the scene. Deputy Chipman’s report stated that [u]pon arrival contact was made with Heath Leet (WM 1/19/84) who stated he was outside painting around 0300 hours on 12/17/18 and his newest roommate [sic], Jessica Morgan (WF 11/26/91), stated she was not feeling good and went back inside. I told Heath that I knew Jessica had been deceased longer than he said and Heath stated that that was not what Taylor told him. I told Heath that he told me he spoke to Jessica 24 hours ago.

(Rec. Doc. 1 at ¶ 15).

The coroner estimated that Morgan had been dead for 24 to 48 hours at the time IPSD arrived on the scene. (Id. at ¶ 16). Deputy Chipman’s report further stated that Heath changed his story about Jessica’s living arrangements multiple times. First Jessica was a roommate [sic], then she was just hanging around with Taylor, then stated Jessica had been living there for 3 days because she just got out of jail.

2 The briefing occasionally refers to Maturin as “Mautrin.” (See Rec. Docs. 8, 21). (Id. at ¶ 18). Leet alleges that these portions of Deputy Chipman’s report are materially false. First, Leet asserts that Deputy Chipman’s own body camera footage contradicts her statement that he identified Morgan as his “roommate.” (Id. at ¶ 17). Next, Leet points out that his written statement, obtained by Deputy Chipman, plainly identifies the person with whom he was painting as “Tay,” meaning Taylor Maturin. (Id. at ¶ 17). Leet claims that these misrepresentations, incorporated into Deputy Cotone’s March 13, 2019 affidavit, were instrumental to the probable cause finding required to secure a warrant for his arrest.3 (Id.

at ¶ 20). Following his arrest, Leet was jailed and later arraigned on July 17, 2019. Leet was released on bail on October 13, 2019. (Id. at ¶ 26). All charges were dismissed on May 5, 2023. (Id. at ¶ 24). Leet filed the instant suit on May 3, 2024, asserting Fourth, Fifth, and Fourteenth Amendment claims pursuant to 42 U.S.C. §§ 1983 and 1988, as well as corresponding state law claims under Louisiana’s Constitution and statutes. (Id. at ¶ 1). The Complaint named Deputy Cotone, Deputy Chipman, Iberia Parish, Iberia Parish Sheriff’s Office, Louis M. Ackal (former Sheriff of Iberia Parish), and Thomas Romero (current Sheriff of Iberia Parish). (Id. at ¶¶ 5–10). Applicable Standard Rule 12(b)(4) is the appropriate procedural device under which to contest the sufficiency of process. “An objection under Rule 12(b)(4) concerns the form of the process rather than the manner or method of its service.” Gartin v. Par Pharm. Cos., 289 F. App’x

3 This Court notes that, although referenced in Leet’s Complaint (Rec. Doc. 1), no party has filed a copy of the affidavit or body camera footage into the record of this case as of the date of this Report and Recommendation. 688, 691 n. 3 (5th Cir. 2008) (citing C. Wright & A. Miller, 5B FEDERAL PRACTICE AND PROCEDURE: 3d § 1353). Rule 12(b)(4) encompasses allegations that a party was not accurately named in the complaint. Id. When considering a motion to dismiss for failure to state a claim under Rule 12(b)(6), the district court must limit itself to the contents of the pleadings, including any attachments and exhibits thereto. Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498 (5th Cir. 2000); U.S. ex rel. Riley v. St. Luke’s Episcopal Hosp., 355 F.3d 370, 375 (5th Cir. 2004). When

reviewing a motion to dismiss, a district court may also consider “documents incorporated into the complaint by reference and matters of which a court may take judicial notice.” Funk v. Stryker Corp., 631 F.3d 777, 783 (5th Cir. 2011) (citing Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 322 (2007)). The court must accept all well-pleaded facts as true and view them in the light most favorable to the plaintiff. In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (internal quotations omitted) (quoting Martin K. Eby Constr. Co. v. Dallas Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004)); Baker v. Putnal, 75 F.3d 190, 196 (5th Cir. 1996). However, conclusory allegations and unwarranted deductions of fact are not accepted as true, Kaiser Aluminum & Chem. Sales v. Avondale Shipyards, 677 F.2d 1045, 1050 (5th Cir. 1982) (citing Associated Builders, Inc. v. Alabama Power Co., 505 F.2d 97, 100 (5th Cir. 1974)); Collins v. Morgan Stanley, 224 F.3d at 498. Courts “are not bound to accept as true a legal conclusion couched as a factual allegation.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Papasan v.

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