UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION
] MAYA DELION & ] JACOB GOODSON, ] ] ] Plaintiffs, ] ] v. ] 7:25-cv-2058-EGL; ] 7:26-cv-2-EGL TOWN OF WOODSTOCK, et al., ] ] ] Defendants. ]
MEMORANDUM OPINION In two now-consolidated cases,1 Maya Delion and Jacob Goodson have sued the City of Woodstock, Alabama; the Bibb County Commission; UAB Hospital; UAB Medical West; John Does 1-200; and Fictitious Defendants A-E. Doc. 1. The Bibb County Commission, the City of Woodstock, UAB Hospital, and Medical West ask the Court to dismiss the complaint for various reasons. See Docs. 7-9, 12, 15-16, 25, 31-32. For the reasons below, the motions are GRANTED.
1 On February 10, 2026, the Court consolidated Delion v. City of Woodstock, No. 7:25-cv-2058- EGL (N.D. Ala. Dec. 2, 2025), with Delion v. City of Woodstock, No. 7:26-cv-2-EGL (N.D. Ala. Jan. 2, 2026). Unless otherwise specified, all docket citations contained herein refer to the docket in case number 7:25-cv-2058. BACKGROUND Because Delion and Goodson are defending against a motion to dismiss, the
Court accepts their well-pleaded factual allegations as true and construes them in the light most favorable to Plaintiffs. Lanfear v. Home Depot, Inc., 679 F.3d 1267, 1275 (11th Cir. 2012). And because Plaintiffs are proceeding pro se, the Court must
construe their complaint liberally. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). A. Facts Maya Delion owned property in Bibb County, Alabama. Doc. 1 at ¶17. She lived in a home on that property. Id. Her son, Joseph Tyler Goodson (“Tyler”), lived
nearby in a separate residence with his family. Id. In December 2023, police officers from the Woodstock Police Department, the Bibb County Sheriff’s Office, and other agencies entered the property. Id. at ¶¶1-
2. Officers fired toward Tyler’s residence, damaging the home, nearby structures, and vehicles. Id. at ¶¶20-21. They then arrested Tyler and remained with him after he was transported to UAB Hospital. Id. at ¶26. Jacob Goodson witnessed these events. Id. at ¶10.
B. Lawsuit Maya Delion and Jacob Goodson sued under 42 U.S.C. § 1983. Id. at ¶¶30-37. They allege (1) unreasonable seizure of persons under the Fourth
Amendment; (2) unreasonable seizure and destruction of property; (3) emotional and psychological damage suffered as bystanders; (4) the facilitation of unreasonable seizure; and (5) Monell liability against the City of Woodstock and the Bibb County
Commission. Id. Plaintiffs also assert state-law claims for wantonness, trespass, trespass to chattels, and property damage. Id. at 6. Plaintiffs also sued Defendants in the Circuit Court of Bibb County, Alabama,
raising identical claims. See Delion, No. 7:26-cv-2, Doc. 1-1. Defendants removed that case here, after which this Court consolidated the two. Delion, No. 7:26-cv-2, Docs. 1, 19. The Bibb County Commission, the City of Woodstock, UAB Hospital, and
UAB Medical West each move to dismiss. The Bibb County Commission also moves to strike the fictitious parties that Plaintiffs name. Plaintiffs responded to the Bibb County Commission’s motions but failed to respond to any other motion.
A plaintiff’s failure to respond to a motion to dismiss is not fatal. See Walker v. Montgomery Cnty. Bd. of Educ., No. 2:20-cv-00978-WKW-SRW, 2022 WL 421078 at *1 n.2 (M.D. Ala. Jan. 25, 2022); see also Anton v. Nationstar Mortg., LLC, No. 5:11-cv-2619, 2011 WL 13134196, at *3 n.6 (N.D. Ala. Nov. 10, 2011).
Rather, the Court must decide whether it will (1) permit the plaintiffs to file an out- of-time opposition brief; or (2) consider only the defendants’ arguments and the complaint’s allegations. Giummo v. Olsen, 701 F. App’x 922, 925 (11th Cir. 2017). Because Plaintiffs have not sought permission to file a late response, the Court opts for the latter approach.
STANDARD “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”
Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. But those “[f]actual allegations
must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. Although the Court must accept as true all factual allegations in the complaint, that principle does not apply to legal conclusions couched as factual
allegations. Id. ANALYSIS The Court first addresses the sufficiency of Plaintiffs’ pleadings. It then considers Plaintiffs’ failure to respond to UAB Hospital’s and Medical West’s
motions to dismiss. The Court next evaluates the merits of the claims against UAB Hospital and UAB Medical West. Finally, it analyzes the Bibb County Commission and the City of Woodstock’s potential liability under Monell. I. “Shotgun Pleading” & Fictitious Defendants Federal Rule of Civil Procedure 8(a)(2) requires “a short and plain statement
of the claim showing that the pleader is entitled to relief.” Rule 10(b) requires numbered paragraphs, each limited to a single set of circumstances. These rules combine to compel clarity for the defendants facing claims and for the courts
considering them. See Barmapov v. Amuial, 986 F.3d 1321, 1324 (11th Cir. 2021). They are violated, for example, when plaintiffs assert multiple claims against multiple defendants without specifying which defendant is responsible for which act, or which claim is directed at which defendant. Id. at 1325. Such complaints are
impermissible “shotgun pleadings.” Id. at 1324-25. Plaintiffs name the City of Woodstock, the Bibb County Commission, UAB Hospital, UAB Medical West, “John Does 1-200,” and “Fictitious Defendants A-E”
as defendants. See Doc. 1. Yet they tie no claim, except Count V, to any particular defendant. See id. at 5-6. Instead, they leave each defendant to guess which allegations apply to them. Id. Given the number of defendants, that is an impossible task, particularly where Plaintiffs’ state-law claims lack even the minimal factual
support offered for their federal claims. Id. For example, does UAB Hospital need to defend against claims of trespass to chattels or property damage? Perhaps not, because the complaint contains only a brief mention of the hospital, but maybe,
because the complaint appears to allege nearly every claim against every defendant. The Court need not “parse out such incomprehensible allegations,” Est. of Bass v. Regions Bank, Inc., 947 F.3d 1352, 1358 (11th Cir. 2020), but because the
complaint warrants dismissal on other more significant grounds, this issue is rendered MOOT. Further, fictitious party pleading is generally impermissible in federal court.
Vielma v. Gruler, 808 F. App’x 872, 880 (11th Cir. 2020); Weiland v. Palm Beach Cnty. Sheriff’s Off., 792 F.3d 1313, 1318 n.4 (11th Cir. 2015).
Free access — add to your briefcase to read the full text and ask questions with AI
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION
] MAYA DELION & ] JACOB GOODSON, ] ] ] Plaintiffs, ] ] v. ] 7:25-cv-2058-EGL; ] 7:26-cv-2-EGL TOWN OF WOODSTOCK, et al., ] ] ] Defendants. ]
MEMORANDUM OPINION In two now-consolidated cases,1 Maya Delion and Jacob Goodson have sued the City of Woodstock, Alabama; the Bibb County Commission; UAB Hospital; UAB Medical West; John Does 1-200; and Fictitious Defendants A-E. Doc. 1. The Bibb County Commission, the City of Woodstock, UAB Hospital, and Medical West ask the Court to dismiss the complaint for various reasons. See Docs. 7-9, 12, 15-16, 25, 31-32. For the reasons below, the motions are GRANTED.
1 On February 10, 2026, the Court consolidated Delion v. City of Woodstock, No. 7:25-cv-2058- EGL (N.D. Ala. Dec. 2, 2025), with Delion v. City of Woodstock, No. 7:26-cv-2-EGL (N.D. Ala. Jan. 2, 2026). Unless otherwise specified, all docket citations contained herein refer to the docket in case number 7:25-cv-2058. BACKGROUND Because Delion and Goodson are defending against a motion to dismiss, the
Court accepts their well-pleaded factual allegations as true and construes them in the light most favorable to Plaintiffs. Lanfear v. Home Depot, Inc., 679 F.3d 1267, 1275 (11th Cir. 2012). And because Plaintiffs are proceeding pro se, the Court must
construe their complaint liberally. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). A. Facts Maya Delion owned property in Bibb County, Alabama. Doc. 1 at ¶17. She lived in a home on that property. Id. Her son, Joseph Tyler Goodson (“Tyler”), lived
nearby in a separate residence with his family. Id. In December 2023, police officers from the Woodstock Police Department, the Bibb County Sheriff’s Office, and other agencies entered the property. Id. at ¶¶1-
2. Officers fired toward Tyler’s residence, damaging the home, nearby structures, and vehicles. Id. at ¶¶20-21. They then arrested Tyler and remained with him after he was transported to UAB Hospital. Id. at ¶26. Jacob Goodson witnessed these events. Id. at ¶10.
B. Lawsuit Maya Delion and Jacob Goodson sued under 42 U.S.C. § 1983. Id. at ¶¶30-37. They allege (1) unreasonable seizure of persons under the Fourth
Amendment; (2) unreasonable seizure and destruction of property; (3) emotional and psychological damage suffered as bystanders; (4) the facilitation of unreasonable seizure; and (5) Monell liability against the City of Woodstock and the Bibb County
Commission. Id. Plaintiffs also assert state-law claims for wantonness, trespass, trespass to chattels, and property damage. Id. at 6. Plaintiffs also sued Defendants in the Circuit Court of Bibb County, Alabama,
raising identical claims. See Delion, No. 7:26-cv-2, Doc. 1-1. Defendants removed that case here, after which this Court consolidated the two. Delion, No. 7:26-cv-2, Docs. 1, 19. The Bibb County Commission, the City of Woodstock, UAB Hospital, and
UAB Medical West each move to dismiss. The Bibb County Commission also moves to strike the fictitious parties that Plaintiffs name. Plaintiffs responded to the Bibb County Commission’s motions but failed to respond to any other motion.
A plaintiff’s failure to respond to a motion to dismiss is not fatal. See Walker v. Montgomery Cnty. Bd. of Educ., No. 2:20-cv-00978-WKW-SRW, 2022 WL 421078 at *1 n.2 (M.D. Ala. Jan. 25, 2022); see also Anton v. Nationstar Mortg., LLC, No. 5:11-cv-2619, 2011 WL 13134196, at *3 n.6 (N.D. Ala. Nov. 10, 2011).
Rather, the Court must decide whether it will (1) permit the plaintiffs to file an out- of-time opposition brief; or (2) consider only the defendants’ arguments and the complaint’s allegations. Giummo v. Olsen, 701 F. App’x 922, 925 (11th Cir. 2017). Because Plaintiffs have not sought permission to file a late response, the Court opts for the latter approach.
STANDARD “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”
Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. But those “[f]actual allegations
must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. Although the Court must accept as true all factual allegations in the complaint, that principle does not apply to legal conclusions couched as factual
allegations. Id. ANALYSIS The Court first addresses the sufficiency of Plaintiffs’ pleadings. It then considers Plaintiffs’ failure to respond to UAB Hospital’s and Medical West’s
motions to dismiss. The Court next evaluates the merits of the claims against UAB Hospital and UAB Medical West. Finally, it analyzes the Bibb County Commission and the City of Woodstock’s potential liability under Monell. I. “Shotgun Pleading” & Fictitious Defendants Federal Rule of Civil Procedure 8(a)(2) requires “a short and plain statement
of the claim showing that the pleader is entitled to relief.” Rule 10(b) requires numbered paragraphs, each limited to a single set of circumstances. These rules combine to compel clarity for the defendants facing claims and for the courts
considering them. See Barmapov v. Amuial, 986 F.3d 1321, 1324 (11th Cir. 2021). They are violated, for example, when plaintiffs assert multiple claims against multiple defendants without specifying which defendant is responsible for which act, or which claim is directed at which defendant. Id. at 1325. Such complaints are
impermissible “shotgun pleadings.” Id. at 1324-25. Plaintiffs name the City of Woodstock, the Bibb County Commission, UAB Hospital, UAB Medical West, “John Does 1-200,” and “Fictitious Defendants A-E”
as defendants. See Doc. 1. Yet they tie no claim, except Count V, to any particular defendant. See id. at 5-6. Instead, they leave each defendant to guess which allegations apply to them. Id. Given the number of defendants, that is an impossible task, particularly where Plaintiffs’ state-law claims lack even the minimal factual
support offered for their federal claims. Id. For example, does UAB Hospital need to defend against claims of trespass to chattels or property damage? Perhaps not, because the complaint contains only a brief mention of the hospital, but maybe,
because the complaint appears to allege nearly every claim against every defendant. The Court need not “parse out such incomprehensible allegations,” Est. of Bass v. Regions Bank, Inc., 947 F.3d 1352, 1358 (11th Cir. 2020), but because the
complaint warrants dismissal on other more significant grounds, this issue is rendered MOOT. Further, fictitious party pleading is generally impermissible in federal court.
Vielma v. Gruler, 808 F. App’x 872, 880 (11th Cir. 2020); Weiland v. Palm Beach Cnty. Sheriff’s Off., 792 F.3d 1313, 1318 n.4 (11th Cir. 2015). It is only permitted where the fictitious label is mere surplusage because the plaintiff’s description of the defendant is sufficiently clear to allow service of process. Vielma, 808 F. App’x at
880. Plaintiffs here name two hundred “John Doe” defendants, and five “Fictitious Defendants.” See Doc. 1 at ¶¶13-14. The descriptions given of these defendants are
not so specific as to render their fictitious styling mere surplusage. See id. And because neither federal law nor the rules of procedure provide any basis for fictitious party practices, the Court STRIKES these fictitious defendants from the complaint. II. Claims Against UAB Hospital
Despite the complaint’s lack of clarity regarding which allegations apply to which defendants, for the sake of judicial economy, the Court will venture to connect the dots. See Fed. R. Civ. P. 1. The only plausible claim that might be alleged against
UAB Hospital appears to be Count IV: “Continued Unreasonable Seizure (Hospital Custody).” Doc. 1 at ¶33. Plaintiffs allege that UAB Hospital personnel “permitted or facilitated” Tyler’s unlawful seizure while he was unconscious. Id. at ¶¶15-16.
They bring these claims under 42 U.S.C. § 1983, asserting violations of Tyler’s Fourth Amendment rights and their “familial rights.” Id. at ¶33. Sovereign immunity bars suits against state agencies absent consent or valid
abrogation. See Eubank v. Leslie, 210 F. App’x 837, 844-45 (11th Cir. 2006). Congress did not abrogate state sovereign immunity in § 1983, and Alabama has not waived its immunity. See Schopler v. Bliss, 903 F.2d 1373, 1379 n.4 (11th Cir. 1990); ALA. CONST. art. I, § 14.
Whether an entity is “an arm of the state” and therefore entitled to sovereign immunity “is a question of federal law that can be answered only after considering the provisions of state law that define the agency’s character.” Galette v. New Jersey
Transit Corp., No. 24-1021, 2026 WL 598450, at *6 (U.S. Mar. 4, 2026) (internal quotation marks omitted). UAB and its hospital operate as a division of the Board of Trustees of the University of Alabama, and the Board, rather than UAB Hospital, constitutes the
proper defendant. See Strickland v. Bd. of Trs. of Univ. of Ala., No. 2:14-cv-1389- WMA, 2014 WL 6749019, at *2 (N.D. Ala. Dec. 1, 2014); Wiley v. Dep’t of Energy, No. 21-cv-933, 2021 WL 5051952, at *1 n.1 (E.D. La. Nov. 1, 2021). The Alabama
Supreme Court and the Eleventh Circuit consider Alabama’s state universities, including the boards governing them, to be state agencies for sovereign immunity purposes. See Harden v. Adams, 760 F.2d 1158, 1163-64 (11th Cir. 1985); Eubank,
210 F. App’x at 844 (“The University of Alabama Board of Trustees is a state agency, not a state official acting in its official capacity” for sovereign immunity purposes); Page v. Hicks, 773 Fed. App’x 514, 518 (11th Cir. 2019); Liberty Nat. Life Ins. Co.
v. Univ. of Ala. Health Servs. Found., P.C., 881 So. 2d 1013, 1027-28 (Ala. 2003); Rowell v. Fisher, No. 2:23-cv-00034-LSC-HNJ, 2024 WL 4480133, at *4-8 (N.D. Ala. Sept. 16, 2024) (evaluating thoroughly whether “UAB hospital” is protected by sovereign immunity), report and recommendation adopted, No. 2:23-cv-00034-
LSC-HNJ, 2024 WL 4476660 (N.D. Ala. Oct. 11, 2024). Because “UAB Hospital”—really the Board of Trustees of the University of Alabama—is an arm of the State of Alabama, it is protected by sovereign immunity
and this Court lacks subject-matter jurisdiction over the claims asserted against it. Accordingly, the Court must dismiss them. III. Claims Against UAB Medical West Like the claims brought against UAB Hospital, the only claim potentially
relevant to UAB Medical West appears to be Count IV. See Doc. 1 at ¶33. Plaintiffs, however, sued the wrong entity. UAB Medical West dissolved in 2017 after transferring its assets to The Health Care Authority for Medical West, which later reincorporated as Medical West Hospital Authority. See Doc. 12 at ¶1; Doc. 12-1 at 2-4.
Plaintiffs mailed the summons to “UAB Medical West, an Affiliate of UAB Health Sysem, c/o CT Corporation System, Registered Agent 2, North Jackson St., Suite 605, Montgomery, AL 36104.” Doc. 12-1 at 4 (citing Doc. 4). But Medical
West’s registered address is 701 20th Street South, Suite 820, Birmingham, Alabama, 35233, and its registered agent is W. John Daniel. Doc. 12-3 at 1. On this basis, Medical West moves to dismiss for insufficient service of process and lack of personal jurisdiction under Rules 12(b)(2) and (5). Doc. 12-1 at
4. Plaintiffs had 90 days from filing to perfect service. See Fed. R. Civ. P. 4(m); Doc. 1. Ordinarily, the Court would refrain from resolving the case on the merits before being assured of personal jurisdiction. See Posner v. Essex Ins. Co., 178 F.3d 1209,
1214 n.6 (11th Cir. 1999). But a more critical flaw demands immediate attention: Plaintiffs lack standing, and therefore the Court lacks subject-matter jurisdiction. Standing exists when (1) the plaintiff suffered an injury in fact; (2) the injury is fairy traceable to the defendant; and (3) it is likely that the injury will be redressed
by a favorable judicial decision. Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61 (1992). The Court need not address whether Plaintiffs can, as third parties, assert the
Fourth Amendment violations they allege Tyler suffered; or whether the alleged interference with their “familial rights” is sufficiently concrete to constitute a legally cognizable injury. That is because traceability is clearly absent since Plaintiffs do
not demonstrate any causal link between their allegations and Medical West. Article III traceability requires more than “bare speculation.” Deep S. Ctr. for Env’t Just. v. United States Env’t Prot. Agency, 138 F.4th 310, 326 (5th Cir. 2025);
Parsons v. U.S. Dep’t of Justice, 801 F.3d 701, 714 (6th Cir. 2015) (concluding that, for purposes of traceability, “causation means more than speculative but less than but-for”). Plaintiffs allege that Tyler received medical care at UAB Hospital. Doc. 1 at
¶26. But nothing connects those allegations to Medical West. Instead, Plaintiffs confess that they only named Medical West “to preserve claims related to any role it played” in Tyler’s seizure following the shooting. Id. at ¶16. But Plaintiffs have not
developed that possibility into any specific allegation of wrongdoing. Thus the claims against Medical West rely solely on speculation that it might have played some role in causing Plaintiffs’ harm. Plaintiffs have therefore not traced their injuries to Medical West; rather, the allegations as they stand suggest that their harm
is attributable to “the independent action of some third party.” Corbett v. Transp. Sec. Admin., 930 F.3d 1225, 1232 (11th Cir. 2019). Because Plaintiffs fail to trace their injuries to Medical West, they lack standing. Accordingly, the Court lacks subject-matter jurisdiction and must dismiss
the claims against Medical West. IV. Claims Against the Bibb County Commission & City of Woodstock Plaintiffs attempt to state a claim against the Bibb County Commission and
the City of Woodstock under 42 U.S.C. § 1983 alleging “constitutional injuries” resulting from their failure to train and supervise officers regarding use of force. See Doc. 1 at ¶¶34-37. A. City of Woodstock
In 1978, the Supreme Court held that municipalities may be liable under § 1983. See Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 694 (1978). Municipalities may be liable only for their own unconstitutional or illegal policies or customs, but
not for the acts of their employees. Id. at 693-94. Thus, a municipality is not automatically liable under § 1983 “even if it inadequately trained or supervised its police officers” and those officers violated someone’s rights. Gold v. City of Miami, 151 F.3d 1346, 1350 (11th Cir. 1998). Instead, there are only limited circumstances
in which an allegation of a failure to train or supervise can be the basis for liability under § 1983. Id. These limited circumstances occur only “where the municipality inadequately trains or supervises its employees, this failure to train or supervise is a
city policy, and that city policy causes the employees to violate a citizen’s constitutional rights.” Id. Because municipalities rarely possess an express “policy of inadequately training or supervising its employees,” a plaintiff may prove the
existence of such a “policy by showing that the municipality’s failure to train evidenced a ‘deliberate indifference’ to the rights of its inhabitants….” Id. To establish deliberate indifference, a plaintiff must present some evidence
that the municipality “knew of a need to train and/or supervise in a particular area” and the municipality “made a deliberate choice not to take any action.” Id. Absent such notice, a municipality is not liable as a matter of law for any failure to train or supervise. Id. at 1351. Such notice can be established, for example, by showing a
history of widespread prior abuse, or a pattern of incidents putting the city on notice of a need to train its employees. Id. at 1351-52. In Brooks v. Scheib, the Eleventh Circuit held that, though there had been ten citizen complaints about a city’s police
officer, the city did not have any notice of past police misconduct because the plaintiff “never demonstrated that past complaints of police misconduct had any merit.” 813 F.2d 1191, 1193 (11th Cir. 1987). This high standard of proof is “intentionally onerous for plaintiffs” because “imposing liability on a municipality
without proof that a specific policy caused a particular violation” would “equate to subjecting the municipality to respondeat superior liability—a result never intended by section 1983.” Gold, 151 F.3d at 1351 n.10. Plaintiffs contend that the City of Woodstock failed to train or supervise its officers regarding “crisis response, firearms use, interagency coordination, and
unified command” and that its “practices, customs, or policies” “allowed or enabled reckless use of force and lack of coordination.” Doc. 1 at ¶¶34-36. But they identify no practice, custom, or policy producing their alleged harm,
and they point to no facts supporting those allegations. Neither do they allege that the City of Woodstock was deliberately indifferent to the possibility of such violations, nor do they allege any incidents that might have put the city on notice of a need to supervise or train its officers on these issues. “To establish a policy or
custom, it is generally necessary to show a persistent and wide-spread practice.” Depew v. City of St. Marys, Ga., 787 F.2d 1496, 1499 (11th Cir. 1986). “Generally, a plaintiff must show multiple similar, past, meritorious complaints against a police
force to prove a custom condoning excessive force.” White v. City of Birmingham, Ala., 96 F. Supp. 3d 1260, 1282 (N.D. Ala. 2015). Even taking everything Plaintiffs allege as true, their allegations are simply insufficient, as a matter of law, to constitute anything approximating liability under Monell. For that reason, their
claims against the City of Woodstock fail and must be dismissed. B. Bibb County Commission Local government entities cannot be liable for the acts of individuals not under
their authority. Turquitt v. Jefferson Cnty., 137 F.3d 1285, 1292 (11th Cir. 1998). The Court must instead look to “which government body, under state law, had direct control over how the [officers] fulfilled [the duty at issue].” Id.
The Alabama Constitution designates sheriffs and deputy sheriffs as state employees. ALA. CONST. art. V, § 112. While each county has a sheriff, “sheriffs” are “executive officers of the State,” and “a deputy sheriff is the alter ego of the
sheriff.” Ex parte Underwood, No. SC-2024-0263, 2025 WL 1776225, at *2, 4 (Ala. June 27, 2025). The sheriff has “exclusive authority to hire, fire, and train deputies.” Cofield v. Randolph Cnty. Comm’n, 844 F. Supp. 1499, 1501 (M.D. Ala. 1994). In contrast, county commissions are “creatures of statute” that have “no
inherent powers.” Dillard v. Baldwin Cnty. Comm’n, 833 So. 2d 11, 16 (Ala. 2002). Any authority a county commission has must come from a statutory directive. Id. Alabama law requires counties to provide facilities and equipment to law
enforcement but does not authorize counties to “assist the sheriff in fulfilling his police function.” Cofield, 844 F. Supp. at 1501. “Because sheriffs and their deputies are state officers not county employees, a county commission may not be held liable on the theory of respondeat superior.” Id. Thus, the Bibb County Commission cannot
be held liable for any actions that Plaintiffs allege were taken by the Bibb County Sheriff’s Office. Under Alabama law, the Bibb County Police Department is the government
body with authority over police officers within Bibb County, not the Bibb County Commission. Without such supervisory authority, “a county commission may not be held liable for failing to train [officers].” /d. Plaintiffs’ barebones assertion that the Commission has a “statutory role in supporting and overseeing county-involved operations” is unsupported by any legal authority and runs counter to Alabama law. Doc. 22 at 4. Accordingly, their claims against the Commission on that basis fail as
a matter of law and must be dismissed. CONCLUSION Plaintiffs’ complaint is an impermissible “shotgun pleading” and engages in illicit fictitious-party pleading. The Court lacks subject-matter jurisdiction to hear Plaintiffs’ claims against UAB Hospital and Medical West. Plaintiffs do not allege facts that would support a § 1983 claim against the City of Woodstock under Monell, and therefore their claims against it fail as a matter of law. And Plaintiffs have failed to state a claim against the Bibb County Commission. Accordingly, the Court STRIKES the fictitious defendants, DISMISSES the claims against UAB Hospital and the Bibb County Commission WITH PREJUDICE, and DISMISSES the claims against Medical West and the City of Woodstock WITHOUT PREJUDICE. DONE and ORDERED this 20th day of March, 2026.
EDMUND G.LACOURJR. UNITED STATES DISTRICT JUDGE