Rector v. Eskridge

CourtDistrict Court, S.D. Texas
DecidedMay 27, 2025
Docket4:25-cv-01510
StatusUnknown

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

Bluebook
Rector v. Eskridge, (S.D. Tex. 2025).

Opinion

Southern District of Texas ENTERED IN THE UNITED STATES DISTRICT COURT N thar □□□□□□□ erk FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION LONNIE HENRY RECTOR, JR., § Plaintiff; Vv. Civil Action No. H-25-1510 HON. CHARLES ESKRIDGE, Defendant. MEMORANDUM OPINION AND ORDER State prisoner Lonnie Henry Rector, Jr., proceeding pro se and in forma pauperis, filed an amended complaint against Charles Eskridge, a federal district judge in the United States District Court for the Southern District of Texas, under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). (Docket Entries No. 9, 9-1.) Having screened the amended complaint under 28 U.S.C. § 1915(e) and § 1915A, the Court DISMISSES this lawsuit for the reasons shown below. I, BACKGROUND AND CLAIMS Rector names the Honorable Charles Eskridge as the sole defendant in his amended complaint. (Docket Entry No. 9, section IV(B).) He states that on an undisclosed date, he filed a federal habeas petition under 28 U.S.C. § 2241 in the United States District Court for the Eastern District of Texas, challenging a conviction that arose in the Southern District of

Texas. He complains that the Eastern District court transferred the petition to the Southern : District in April-May 2024 “and ruled against plaintiff.” Jd., section V. Rector claims that

the transfer and dismissal of his habeas petition violated his constitutional rights, as “the

essence of civil liberty consists in the right of every individual to claim the protection of the

laws whenever he receives an injury.” Jd. He requests no specific judicial relief, asking for

“what the court deems just, proper, and equitable.” Jd., section VI. A review of public online records for this Court shows that Rector filed a § 2241 habeas petition in the Eastern District of Texas on April 22, 2024, challenging the constitutionality ofhis 1996 Harris County, Texas conviction and enhanced life sentence for aggravated robbery. The Eastern District court construed the § 2241 petition as one brought under § 2254, and transferred it to this Court on May 2, 2024, where it was assigned to Judge Eskridge. Rector v. Lumpkin, C.A. No. H-24-1741 (S.D. Tex.). Judge Eskridge dismissed the petition without prejudice on May 30, 2024, as an unauthorized successive habeas petition. No appeal was taken. If. ANALYSIS A. Standard of Review Because Rector has been granted leave to proceed in forma pauperis, the Court is required by statute to review and screen the amended complaint. Under 28 U.S.C. § 1915(e)(2), “the court shall dismiss the case at any time if the court determines that . . . the

action or appeal (i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief.”

28 U.S.C. § 1915(e)(2).

A complaint is frivolous if it “lacks an arguable basis either in law or in fact.” Neitzke

vy. Williams, 490 U.S. 319, 325, (1989); Samford v. Dretke, 562 F.3d 674, 678 (Sth Cir.

2009). A claim lacks an arguable basis in law when it is “based on an indisputably meritless

legal theory.” Neitzke, 490 U.S. at 327. A claim lacks an arguable basis in fact when the

facts alleged are fantastic or delusional scenarios or the legal theory upon which it relies is

indisputably meritless. Harris v. Hegmann, 198 F.3d 153, 156 (Sth Cir. 1999). B. Official Capacity Claims under Bivens Rector does not specify whether he sues Judge Eskridge in his official or individual

capacity. To the extent he sues Judge Eskridge in his official capacity as a federal judicial officer, his suit is effectively against the United States government, which is entitled to

sovereign immunity from suit. Smart v. Holder, 368 F. App’x 591, 593 (Sth Cir. 2010) (“[S]uits against federal officers in their official capacity are really suits against the

government.”). “The United States enjoys sovereign immunity from suit, meaning it cannot

be sued without consent.” Gonzalez v. United States, 851 F.3d 538, 543 (Sth Cir. 2017) (citations omitted). Accordingly, a plaintiff may sue the United States only if a federal statute specifically waives sovereign immunity. In re FEMA Trailer Formaldehyde Prods.

Liab. Litig., 668 F.3d 281, 287 (5th Cir. 2012); see also Wagstaff U.S. Dep’t of Educ., 509

F.3d 661, 664 (5th Cir. 2007) (“In order to hale the federal government into a court

proceeding, a plaintiff must show that there has been a valid waiver of sovereign immunity.”). Any waiver of the sovereign immunity of the United States must clearly appear

in statutory text and cannot be implied. Wagstaff; 509 F.3d at 664. Rector has not identified

any waiver of sovereign immunity applicable to his claims. Accordingly, Rector’s claims against Judge Eskridge in his official capacity are dismissed with prejudice. C. Individual Capacity Claims under Bivens To the extent Rector sues Judge Eskridge in his individual capacity, the legal basis for such suit would need to arise under Bivens. Bivens provides a cause of action only against federal government officers in their individual capacities. Affiliated Pro. Home Health Care Agency v. Shalala, 164 F.3d 282, 286 (Sth Cir. 1999). Even so, Bivens has limited application. “The Supreme Court has authorized an implied damages remedy against federal officers for constitutional violations (Bivens actions) only three times.” Springer v. United States, 2022 WL 2208516, at *1 (Sth Cir. June 21, 2022) (citing Carlson v. Green, 446 U.S. 14 (1980) (Eighth Amendment claim under Bivens for failure to provide adequate medical assistance to an inmate); Davis v. Passman, 442 U.S. 228 (1979) (Fifth Amendment Due Process claim under Bivens for gender discrimination); Bivens (Fourth Amendment claim for unreasonable search and seizure)). As explained by the Supreme Court of the United States, “the Court has made clear that expanding the Bivens remedy is now a ‘disfavored’ judicial activity.” Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009). “Bivens does not extend to new contexts —that is, those that are different in a meaningful

way from previous Bivens cases decided by the Supreme Court.” Springer, at *1 (cleaned up); see also Butler v. S. Porter, 999 F.3d 287, 294 (Sth Cir. 2021).

Bivens has not been extended to civil claims against federal district judges of the

nature raised here, and this Court is not at liberty to create such an extension in Rector’s instance. Accordingly, Rector’s claims against Judge Eskridge in his individual capacity are dismissed with prejudice. D. Judicial Immunity “As a class, judges have long enjoyed a comparatively sweeping form of immunity.” Forrester v.

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

Related

Harris v. Hegmann
198 F.3d 153 (Fifth Circuit, 1999)
Ballard v. Wall
413 F.3d 510 (Fifth Circuit, 2005)
Wagstaff v. United States Department of Education
509 F.3d 661 (Fifth Circuit, 2007)
Samford v. Dretke
562 F.3d 674 (Fifth Circuit, 2009)
Brewster v. Dretke
587 F.3d 764 (Fifth Circuit, 2009)
Michael Smart v. Eric Holder
368 F. App'x 591 (Fifth Circuit, 2010)
Pierson v. Ray
386 U.S. 547 (Supreme Court, 1967)
Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Forrester v. White
484 U.S. 219 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Teresa Gonzalez v. USA
851 F.3d 538 (Fifth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Rector v. Eskridge, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rector-v-eskridge-txsd-2025.