Sanchez v. Justice

CourtDistrict Court, W.D. Louisiana
DecidedAugust 29, 2025
Docket1:24-cv-00513
StatusUnknown

This text of Sanchez v. Justice (Sanchez v. Justice) 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
Sanchez v. Justice, (W.D. La. 2025).

Opinion

d UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA ALEXANDRIA DIVISION

JUANA IDALIA SANCHEZ, CIVIL DOCKET NO. 1:24-CV-00513 Plaintiff

VERSUS JUDGE TERRY A. DOUGHTY

JUSTICE, MAGISTRATE JUDGE PEREZ-MONTES Defendants

REPORT AND RECOMMENDATION Plaintiff Juana Idalia Sanchez (“Sanchez”) filed this lawsuit against the United States Department of Justice, Federal Bureau of Prisons (the “BOP”), under the Federal Tort Claims Act, 28 U.S.C. § 1346(b)(1) (“FTCA”). Sanchez’s husband died while incarcerated at the United States Penitentiary in Pollock, Louisiana (“USP-Pollock”). While his death was deemed a suicide, Sanchez takes issue with that finding, and claims that the BOP tortiously caused or contributed to her husband’s death while charged with his custody and safety. The BOP now moves to dismiss Sanchez’s negligence and related claims under Fed. R. Civ. P. 12(b)(1) and the discretionary function exception (“DFE”) to the FTCA, The BOP also challenges her wrongful death claim under Fed. R. Civ. P. Rule 12(b)(6). The the DFE does apply to Sanchez’s relevant claims because they do not implicate a nondiscretionary duty imposed upon the BOP. Sanchez has, relatedly, failed to state a viable claim to recover damages for wrongful death. Therefore, IT IS RECOMMENDED that the Motion to Dismiss (ECF No. 31) be GRANTED. The DFE applies to each of Sanchez’s relevant claims, and Sanchez has not stated a viable claim to recover damages for wrongful death. Therefore, IT IS RECOMMENDED that the Motion to Dismiss (ECF No. 31) be GRANTED, and that

Sanchez’s claims be DISMISSED WITHOUT PREJUDICE. I. Background On November 5, 2020, officers at USP-Pollock discovered Alex Sanchez in his isolation cell hanging by his neck from a tan-colored cloth. He died from asphyxiation. Sanchez is his surviving wife, and she filed this FTCA and wrongful death lawsuit. The circumstances surrounding Alex Sanchez’s death – including the decisions

regarding his supervision at USP-Pollock and the investigation following his death – form the basis of the lawsuit. Alex Sanchez had recently been transferred to USP-Pollock from the United States Penitentiary in Beaumont, Texas (“USP-Beaumont”). Sanchez alleges that he had received serious threats at USP-Beaumont, which is the reason he was transferred. Alex Sanchez requested protective accommodations, and was subsequently transferred to USP-Pollock on October 16, 2020. Due to COVID-19

protocols in effect at the time, he was placed in a minimum 14-day quarantine when he arrived at USP-Pollock – meaning he was housed almost exclusively in isolation until his death. Sanchez claims, however, that despite knowing about the threats at USP-Beaumont, officers at USP-Pollock failed to provide proper care and protection to Alex Sanchez before his death. Sanchez also challenges the determination that Alex Sanchez died by suicide. After his death, the Grant Parish Coroner conducted a forensic examination and determined that he died as a result of “asphyxia due to hanging,” classifying the

manner of death as suicide. The coroner’s report did not note any signs of struggle or injuries inconsistent with suicide, aside from a wound around Sanchez’s neck and minor contusions on his knee and thigh. Upon receiving her husband’s body in Laredo, Texas, however, Sanchez alleges she observed additional markings and injuries not documented in the initial forensic report, and which she believed were inconsistent with suicide. At her request, a

second autopsy was performed in Laredo by Dr. Corinne E. Stern on November 15, 2020. Dr. Stern’s report confirmed death by asphyxiation but stated that it could not be determined whether the injury was caused by hanging or ligature strangulation. Dr. Stern also noted head trauma and other contusions not described in the coroner’s report, raising questions about the circumstances of Sanchez’s death. Sanchez also contends that the BOP failed to properly train and supervise its staff, did not follow required investigatory and reporting protocols after Alex’s death,

and deliberately misinformed her regarding the circumstances of his death. She asserts that lapses in these protocols left the coroner’s report as the sole official determination of suicide, despite what she saw as unresolved questions. This lawsuit followed. Sanchez asserts claims for: • negligence and gross negligence, negligent training, negligent supervision, and negligent failure to properly investigate (the “Negligence Claims”); • intentional infliction of emotional distress ( the “IIED Claim”); and • wrongful death.1 The BOP denies liability overall, and maintains that any acts or omissions at issue

were discretionary, and therefore cannot form the basis for FTCA or wrongful death liability. II. Law and Analysis A. The Negligence and IIED Claims

The BOP argues that Sanchez’s Negligence and IIED Claims should be dismissed for lack of subject matter jurisdiction. 1. Fed. R. Civ. P. 12(b)(1)

Under Fed. R. Civ. P. 12(b)(1), a party may seek dismissal for “lack of subject- matter jurisdiction.” Fed. R. Civ. P. 12(b)(1). “The party asserting jurisdiction bears the burden of proof and must establish, by a preponderance of the evidence, that the court has jurisdiction based on: ‘(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.’” , 982 F.3d 937, 940 (5th Cir. 2020), (Dec. 30, 2020) (internal citations and quotation omitted).2

1 Sanchez filed this lawsuit under the FTCA, originally in the United States District Court for the Southern District of Texas. The case was transferred to this Court on April 17, 2024. ECF No. 18.

2 A court’s dismissal under Rule 12(b)(1) should generally be without prejudice, because that decision “is not a determination of the merits and does not prevent the plaintiff from pursuing a claim in a court that does have proper jurisdiction.” , 281 F.3d 158, 161 (5th Cir. 2001). In examining a Rule 12(b)(1) motion, a court is “empowered to consider matters of fact which may be in dispute.” , 281 F.3d 158, 161 (5th Cir. 2001).3 “But there are limits to a district court's ability to resolve fact disputes

on a Rule 12(b)(1) motion.” , 37 F.4th 1013, 1019 (5th Cir. 2022). The “general rule” prohibits “resolution of the jurisdictional issue on a 12(b)(1) motion . . . where the jurisdictional attack is intertwined with the merits of a claim.” (internal citations and quotations omitted). And typically, a Rule 12(b)(1) motion should be granted “only if it appears certain that the plaintiff cannot prove any set of facts in support of his claim that

would entitle plaintiff to relief.” , 9 F.4th 256, 260 (5th Cir. 2021) (internal citations and quotations omitted). 2. The DFE The United States, as a sovereign entity, is immune from suit unless it unequivocally consents to be sued. , 26 F.3d 592, 594 (5th Cir. 1994).

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