Steven Sencial v. Arthur Coll, et al.

CourtDistrict Court, E.D. Louisiana
DecidedJune 9, 2026
Docket2:24-cv-00874
StatusUnknown

This text of Steven Sencial v. Arthur Coll, et al. (Steven Sencial v. Arthur Coll, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steven Sencial v. Arthur Coll, et al., (E.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA STEVEN SENCIAL CIVIL ACTION VERSUS NO. 24-874 ARTHUR COLL, ET AL. SECTION “E” (4)

ORDER AND REASONS Before the Court is a Report and Recommendation1 issued by the magistrate judge, recommending the Court dismiss with prejudice Plaintiff Steven Sencial’s (“Plaintiff”) 42 U.S.C. § 1983 claims against defendants Officers Arthur Coll and A. Galvez (“Officer Defendants”)2 and dismiss without prejudice Plaintiff’s state law claims against the Officer Defendants. Plaintiff filed objections to the Report and Recommendation.3 BACKGROUND At the time he filed this action, Plaintiff was a pretrial detainee housed in the St. Tammany Parish Jail.4 On April 4, 2024, Plaintiff, pro se and proceeding in forma pauperis,5 filed a complaint pursuant to 42 U.S.C. § 1983 against five defendants: Officer Arthur Coll and Officer A. Galvez (“Officer Defendants”); S. Reina, the alleged victim of his alleged crimes; and Bautista Lopez and Rodriguez Cruz, two alleged eyewitnesses.6 Plaintiff’s factual allegations stem from his arrest for an alleged assault occurring on April

1 R. Doc. 31. 2 Id. 3 R. Doc. 33. 4 R. Doc. 8 at p. 1. 5 On April 5, 2024, Petitioner filed a deficient motion for leave to proceed in forma pauperis. R. Doc. 2. The Clerk of Court issued a Notice of Deficiency and ordered Plaintiff to remedy the deficiency by April 29, 2024. R. Doc. 3. On April 12, 2024, Plaintiff filed a new motion for leave to proceed in forma pauperis. R. Doc. 5. The magistrate judge granted this motion. R. Doc. 6. 6 R. Doc. 4. 6, 2022.7 Plaintiff’s complaint is based on three “incidents.”8 The magistrate judge provided a summary of the incidents based on Plaintiff’s complaint: Under a broad reading of [Plaintiff’s] complaint, [he] alleges that he was arrested without probable cause on April 6, 2022, by Officers Coll and Galvez for aggravated assault with a firearm based on the false complaint made by alleged victim Reina. He also claims that Lopez and Cruz were witnesses who gave false statements to the Kenner Police through a translation made by Reina. He contends that all of the defendants ultimately gave false testimony to procure an indictment and to create probable cause for the arrest. He also claims that the bill of information filed July 21, 2023, was based on police testimony that conflicted with the video evidence which disproved that he had a firearm.9

Plaintiff alleges Officer Coll “lied multiple times in the affidavit of arrest . . . to manufacture probable cause where he knew it did not exist[.]”10 Plaintiff alleges Officer Galvez “translated false testimony [from the witnesses] to procure [his] arrest [and] then perjured himself during the motion to suppress the identifications[.]”11 Plaintiff alleges witnesses Lopez and Cruz gave false statements to the Kenner Police to secure his arrest.12 Plaintiff brought claims under § 1983 for abuse of process, defamation, libel, and slander against the victim Reina and claims under § 1983 for false reporting against witnesses Lopez and Cruz.13 Plaintiff also brought state law claims for abuse of process, defamation, libel, slander, and false reporting against Reina and asked that the Court exercise its supplemental jurisdiction over these claims under 28 U.S.C. § 1367.14 Against the Officer Defendants, Plaintiff brought claims under § 1983 for false arrest, malicious prosecution, false translation of testimony, and perjury.15 Lastly, Plaintiff brought state

7 Id. 8 Id. at pp. 9-10. 9 R. Doc. 31, pp. 1-2. 10 R. Doc. 4 at p. 9. 11 Id. at p. 10. 12 Id. at pp. 1-2. 13 Id. at p. 10. 14 Id. at pp. 10-11. 15 Id. at p. 10. law claims for false arrest, malicious prosecution, and defamation against the Officer Defendants, asking the Court to exercise its supplemental jurisdiction over these claims.16 On June 21, 2024, the magistrate judge issued a Report and Recommendation.17 The magistrate judge recommended that Plaintiff’s § 1983 claims against the non-officer Defendants be dismissed with prejudice as frivolous because (1) private citizens are

generally not considered state actors for the purposes of § 1983 liability, and, (2) even if the private citizens conspired or acted jointly with state actors, the claims would be barred under the Heck doctrine.18 The magistrate judge also recommended this Court decline to exercise supplemental jurisdiction over Plaintiff’s state law claims against Reina, Cruz, and Lopez and dismiss these claims without prejudice.19 In addition, the magistrate judge recommended that Plaintiff’s § 1983 claims against the Officer Defendants be stayed because they are “tied to his arrest and indictment” and therefore may be barred by the Heck doctrine.20 As a result, the magistrate judge recommended Plaintiff’s state law claims against the Officer Defendants be stayed “pending the Court’s determination on the ultimate applicability of Heck once the state criminal charges against [Plaintiff] are resolved.”21

Plaintiff filed a motion to reconsider and lift stay because “the pending charges of aggravated assault with a firearm were dismissed on or around March 8, 2024.”22 Plaintiff further asserted that the “[Division] K District Attorney declined to pursue the felony of

16 Id. at pp. 10-11. 17 R. Doc. 8. 18 Id. at 4, 5. 19 Id. at 5. 20 Id. at 8. 21 Id. at 10. 22 R. Doc. 9 at p. 1. aggravated assault with a firearm.”23 The Court construed Plaintiff’s motion as an objection to the magistrate judge’s Report and Recommendation, arguing that the § 1983 and state law claims against the Officer Defendants are no longer barred under the Heck doctrine because the underlying criminal charge of aggravated assault with a firearm no longer exists.24 On March 24, 2025, this Court partially adopted the Report and

Recommendation, dismissing Plaintiff’s § 1983 claims against the non-officer Defendants with prejudice and his state law claims against these Defendants without prejudice.25 The Court then referred the matter to the magistrate judge to make a recommendation on whether the stay on the claims against the Officer Defendants should be lifted.26 On April 22, 2025, the magistrate judge ordered Plaintiff to submit official documentation corroborating that all pending criminal charges against him had been dismissed.27 Plaintiff filed a response, claiming that the charge of aggravated assault with a firearm has been “dismissed or amended.”28 Plaintiff provided a blurry docket sheet from the Jefferson Parish Clerk of Court listing the criminal charges that had been brought against him.29 The magistrate judge found that, next to each of the four charges for aggravated assault with a firearm, there was text that read “ABANDONED.”30 The

magistrate judge interpreted this to mean that the aggravated assault with a firearm charges against Plaintiff had been resolved in his favor, and recommended a lifting of the stay on Plaintiff’s § 1983 and state law claims against the Officer Defendants.31 On August

23 Id. 24 R. Doc. 12 at p. 4. 25 Id. at p. 8. 26 Id. 27 R. Doc. 13 at p. 2. 28 R. Doc. 14 at p. 1. 29 R. Doc. 14-2. 30 R. Doc. 15 at p. 3. 31 Id. at p. 6. 26, 2025, this Court adopted the magistrate judge’s Report and Recommendation lifting the stay.32 On February 24, 2026, the Officer Defendants filed a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(5).33 The Officer Defendants argue service was improper, as neither of them was personally served in this matter.34 The Officer Defendants argue the

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Bluebook (online)
Steven Sencial v. Arthur Coll, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/steven-sencial-v-arthur-coll-et-al-laed-2026.