Ogbebor v. Hardy

CourtDistrict Court, W.D. Louisiana
DecidedJuly 7, 2025
Docket6:24-cv-00313
StatusUnknown

This text of Ogbebor v. Hardy (Ogbebor v. Hardy) 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
Ogbebor v. Hardy, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

EDOSA ADDLEY FESTUS OGBEBOR DOCKET NO. 6:24-cv-00313 SECTION P

VERSUS JUDGE TERRY A. DOUGHTY

KENNETH HARDY, ET AL MAGISTRATE JUDGE WHITEHURST

REPORT AND RECOMMENDATION

Presently before this Court are the original and amended civil rights complaints filed pursuant to 42 U.S.C. § 1983 by pro se plaintiff Edosa Addley Festus Ogbebor (“Ogbebor”). Docs. 1, 11. This matter has been referred to the undersigned for review, report, and recommendation in accordance with the provisions of 28 U.S.C. §636 and the standing orders of the Court. For reasons stated below, IT IS RECOMMENDED that all claims against the following defendants be DENIED and DISMISSED: University of Louisiana at Lafayette, University of Louisiana Lafayette Police Department, City of Lafayette Police Department, Public Defenders Office, Chris Richard, 15th Judicial District Court, Don Landry, Lafayette Parish District Attorney’s Office, Sheriff’s Office Lafayette Parish, Thomas Frederick, A Doguet, Gary Hayes, Emilia Pardo, Austin, Mark Garber, Unknown Supervisory Officers, Unknown Police Chiefs, U.S. Air Force, and Unknown Insurance Companies1. IT IS FURTHER RECOMMENDED that the following claims be dismissed with prejudice as frivolous, for failure to state a claim on which relief can be granted, and for seeking

1 Claims against defendants Kenneth Hardy, Tyler Daigle, Jacob Ortego, David Latisser, Earnest Payne, Wayne Whatley, Cody Hutchinson, Jeff Lavergne, City of Lafayette and Lafayette Consolidated Government will be addressed in a separate Order. money damages against a defendant who is immune from suit: Counts 8, 9, 26, 27, 29, 30, 21, 32, 33, 34, 35, 37, 38, 41, 44, 45, 48, 49, 50, 53, and 57. I. BACKGROUND

Between 2008 and 2025, Mr. Ogbebor was arrested and prosecuted in Louisiana eight different times. On February 29, 2024, he sued numerous defendants under 42 U.S.C. § 1983 for various alleged constitutional violations related to his arrests and prosecutions that occurred thus far. His 164-page pro se complaint included allegations of unlawful arrest, excessive force, illegal search and seizure, due process violations, suppression of his free speech rights, ineffective assistance, prosecutorial misconduct, and systemic failures to train or supervise officers, protect him, or provide adequate redress for his complaints. He sought compensatory and punitive damages and injunctive relief. On May 22, 2024, Judge Doughty adopted the undersigned’s Report and Recommendation (doc. 2) recommending dismissal of the suit pursuant to Louisiana’s statute of limitations. Doc. 3.

Plaintiff appealed the Court’s ruling. Doc. 5. On March 18, 2025, the Fifth Circuit vacated the Court’s order finding that because he is not a prisoner or proceeding in forma pauperis, the district court erred in sua sponte dismissing Ogbebo’s claims as time-barred, while expressing no opinion as to the ultimate merits of the claims or whether they are, in fact, time-barred. Doc. 6. The Fifth Circuit also held that the Court’s failure to construe Ogbebor’s objections to the Magistrate’s Report and Recommendation as a motion to amend and to consider the allegations and claims contained therein was an abuse of discretion. Id. The matter was remanded to this Court for proceedings consistent with that opinion. On May 5, 2025, Plaintiff filed a 156-page Amended Complaint, adding new parties and claims. Doc. 11. The matter is now ripe for review. II. LAW & ANALYSIS A. Frivolity Review Plaintiff is not a prisoner; nor is he proceeding in forma pauperis. Therefore, the screening

provisions of Title 28 U.S.C. §§ 1915 and 1915A are not applicable. However, in Black v. Hornsby, 2014 WL 2535168 (W.D. La., May 15, 2014), this Court relied on Apple v. Glenn, in which the United States Sixth Circuit Court of Appeals recognized a district court's inherent authority to conduct a limited screening procedure, sua sponte, in a fee-paid non-prisoner's complaint, if it appears from the pleadings and exhibits that the allegations are “totally implausible, attenuated, unsubstantial, frivolous, devoid of merit, or no longer open to discussion.” 183 F.3d 477, 479 (6th Cir.1999) (per curiam) (citing Hagans v. Lavine, 415 U.S. 528 (1974)). Although pro se pleadings are liberally construed and held to less stringent standards than formal pleadings drafted by lawyers, Boag v. MacDougall, 454 U.S. 364, 365 (1982) (per curiam); Haines v. Kerner, 404 U.S.

519, 520 (1972), pro se litigants must still meet basic pleading requirements, and a court is not required to conjure allegations on their behalf. See Chao v. Dars of Texas, 2015 WL 6522818, FN 4 (E.D. Tex. 2015). Furthermore, federal courts are courts of limited jurisdiction and have a duty to police the boundaries of their jurisdiction. Therefore, "a district court may, at any time, sua sponte dismiss a complaint for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure when the allegations of a complaint are totally implausible, attenuated, unsubstantial, frivolous, devoid of merit, or no longer open to discussion." Apple, 183 F.3d at 479.2

2 In response to Plaintiff’s request Motions for Default Judgment (docs. 13, 14), the undersigned denied relief, as the defendants in this matter had not yet been served. The Order inadvertently referenced 28 U.S.C. §§ 1915 and B. Section 1983 Federal law provides a cause of action against any person who, under the color of state law, acts to deprive another of any right, privilege, or immunity secured by the Constitution and laws of the United States. 42 U.S.C. § 1983. To hold the defendant liable, a plaintiff must allege facts to show (1) that a constitutional right has been violated and (2) that the conduct complained of was

committed by a person acting under color of federal law; that is, that the defendant was a government actor. See West v. Atkins, 108 S. Ct. 2250, 2254–55 (1988). C. Improper Defendants a. Lafayette Parish District Attorney’s Office, District Attorney Don Landry, Assistant District Attorneys Gary Haynes, Emilia Pardo and Austin

Plaintiff makes allegations of “systemic violations of his constitutional rights” by the District Attorney’s Office, District Attorney Don Landry and Assistant District Attorneys Austin, Gary Haynes, and Emilia Pardo. He contends that the office and individual attorneys have initiated and pursued criminal charges against him absent substantial evidence, lacked transparency in prosecutorial decisions, and coerced plea agreements under duress. Doc. 11, pp. 42-43. Prosecutors have absolute immunity when acting in a quasi-judicial mode. Imbler v. Pachtman, 424 U.S. 409, 106 S.Ct.

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