Luis Degante et al v. USA

CourtDistrict Court, W.D. Louisiana
DecidedNovember 17, 2025
Docket1:22-cv-00662
StatusUnknown

This text of Luis Degante et al v. USA (Luis Degante et al v. USA) 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
Luis Degante et al v. USA, (W.D. La. 2025).

Opinion

a UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA ALEXANDRIA DIVISION

LUIS DEGANTE ET AL #27241-078, CIVIL DOCKET NO. 1:22-CV-00662 Plaintiff SEC P

VERSUS JUDGE DRELL

USA, MAGISTRATE JUDGE PEREZ-MONTES Defendant

REPORT AND RECOMMENDATION Before the Court is a Motion to Dismiss for Lack of Jurisdiction or for Failure to State a Claim, or Alternatively, Motion for Summary Judgment, filed by the United States of America (the “Government”), seeking dismissal of the remaining claim in the Complaint filed by pro se Plaintiff Luis Degante (“Degante”). ECF No. 85. Because the Court lacks jurisdiction, the Motion to Dismiss (ECF No. 85) should be GRANTED, and the Complaint should be DISMISSED WITHOUT PREJUDICE. I. Background Degante is incarcerated at the Federal Correctional Institution in Pollock, Louisiana (“FCI-Pollock”), alleging negligence and medical malpractice by Dr. Markey, his treating provider at FCI-Pollock.. He filed this lawsuit, seeking recovery under: (1) , 403 U.S. 388 (1971), and; (2) the Federal Tort Claims Act, 28 U.S.C. §§ 1346(b), 2671 (“FTCA”). The claim has since been dismissed. Only the FTCA claim remains. The Government seeks dismissal of the Complaint for lack of jurisdiction or failure to state a claim for which relief can be granted, or, alternatively, on summary judgment.

II. Law and Analysis A. Legal Standard Federal courts are courts of limited jurisdiction and may exercise jurisdiction over cases only as expressly provided by the Constitution and laws of the United States. U.S. Const. art. III §§ 1-2; , 511 U.S. 375, 377 (1994); , 437 U.S. 365, 374 (1978). A party may move to dismiss a

complaint for lack of subject matter jurisdiction under Rule 12(b)(1) of the Federal Rules of Civil Procedure. A Rule 12(b)(1) motion must be considered before any other challenge because “the court must find jurisdiction before determining the validity of a claim.” , 27 F.3d 169, 172 (5th Cir. 1994) (internal citation omitted); , 526 U.S. 574, 577 (1999) (“The requirement that jurisdiction be established as a threshold

matter . . . is inflexible and without exception”) (citation and internal quotation marks omitted). The burden of establishing subject-matter jurisdiction lies with the party seeking the federal forum. , 243 F.3d 912, 916 (5th Cir. 2001). When evaluating a motion to dismiss for lack of subject matter jurisdiction, “‘the trial court is free to weigh the evidence and satisfy itself as to the existence of its power to hear the case.’” , 957 F.2d 178, 181 (5th Cir. 1992) (citation omitted). Courts can consider: (1) the complaint alone; (2) the complaint supplemented by undisputed facts

evidenced in the record, or; (3) the complaint supplemented by undisputed facts plus the Court’s resolution of disputed facts. , 667 F.3d 651, 654 (5th Cir. 2012) (collecting cases). When a defendant makes a factual attack as to subject matter jurisdiction by providing affidavits, testimony, or other evidentiary materials, the plaintiff is required to submit facts in support of jurisdiction. The plaintiff has the burden of proving, by a preponderance of the evidence, that the trial court has subject matter

jurisdiction over the claims. , 800 F.2d 488, 490 (5th Cir. 1986); , 644 F.2d 521, 523 (5th Cir.1981). “The plaintiff, as the party asserting jurisdiction, constantly bears the burden of proof that jurisdiction does in fact exist. Thus, at the pleading stage, the plaintiff must allege a plausible set of facts establishing jurisdiction.” , 741 F. Supp. 3d 528, 540 (N.D. Tex. 2024)

(internal citation and quotations omitted). If the plaintiff cannot meet its burden, the court lacks subject matter jurisdiction and the case must be dismissed. Fed. R. Civ. P. 12(h)(3). B. Degante fails to establish subject matter jurisdiction under the FTCA. The FTCA provides a limited waiver of sovereign immunity for certain torts committed by government employees acting within the scope of their employment. 28 U.S.C. § 1346(b); , 912 F.3d 824, 835 (5th Cir. 2019). A government employee is an officer or employee of a federal agency, a member of the military or naval forces, and a person acting on behalf of a federal agency in an official

capacity. 28 U.S.C. § 2671. A contractor with the United States is not a government employee for purposes of the FTCA. ; , 1:18-CV-512, 2019 WL 6999700, at *1 (E.D. Tex. 2019), , 2019 WL 6954152 (E.D. Tex. 2019), , 838 F. App’x 88 (5th Cir. 2021). While courts utilize numerous factors when determining independent contractor status, “[t]he critical factor in determining whether an individual is an employee of the government or an independent contractor is the power of the federal

government to control the detailed physical performance of the individual.” , 18-CV-00074, 2018 WL 3795300, at *4 (W.D. Tex. 2018) (quoting , 142 F.3d 271, 275 (5th Cir. 1998) (internal quotations omitted); , 598 F.3d 210, 214 (5th Cir. 2010) (enumerating the independent contractor factors)). More specifically: In this inquiry, the critical question is ... not whether the agent must comply with federal standards,” , 60 F.3d 1442, 1447 (9th Cir. 1995) , 546 U.S. 43 (2005), or “whether the ... [agent] receives federal money and must comply with federal standards and regulations,” , 776 F.2d at 1264 (quoting , 425 U.S. at 815). Instead, the critical issue is “whether [the agent's] day-to-day operations are supervised by the Federal Government.” , 776 F.2d at 1264 (quoting , 425 U.S. at 815). The Fifth Circuit refers to the test as the “ daily-detailed-control” test. (internal quotation marks omitted). , No. EP-15-CV-00021-KC, 2016 WL 183708, at *4 (W.D. Tex. Jan. 14, 2016). Because the BOP contracts with private physicians to provide care in BOP

facilities, the Fifth Circuit has consistently held that such physicians are independent contractors.

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