The Estate of James Dean Janota v. Love County Board of Commissioners, et al.

CourtDistrict Court, E.D. Oklahoma
DecidedApril 15, 2026
Docket6:24-cv-00326
StatusUnknown

This text of The Estate of James Dean Janota v. Love County Board of Commissioners, et al. (The Estate of James Dean Janota v. Love County Board of Commissioners, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Estate of James Dean Janota v. Love County Board of Commissioners, et al., (E.D. Okla. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

THE ESTATE OF JAMES DEAN JANOTA,

Plaintiff,

v. Case No. 24-CV-326-FAB-GLJ

LOVE COUNTY BOARD OF COMMISSIONERS, et al.,

Defendants.

OPINION AND ORDER BESOSA, Senior District Judge1 Before the Court are four Reports and Recommendations issued by United States Magistrate Judge Gerald L. Jackson. (Docket Nos. 164-167.) Together, the magistrate judge recommends granting all the Motions to Dismiss (Docket Nos. 111, 113, 116, 137, 138) filed by the various defendants in this civil rights and negligence action involving the death of Mr. James Dean Janota. His Estate (“plaintiff”) timely filed Objections to each Report and Recommendation. (Docket Nos. 170-173.) The Court will ultimately adopt the magistrate judge’s recommendations, however, and GRANT all defendants’ Motions to Dismiss.

1 Of the District of Puerto Rico, sitting by designation pursuant to 28 U.S.C. § 292(d). See Docket No. 181. Case No. 24-CV-326-FAB-GLJ 2

BACKGROUND Plaintiff alleges that the Love County Sheriff’s office arrested Mr. Janota on December 3, 2021 in Love County, Oklahoma. (Docket No. 109 at ¶¶ 25-27.) Sheriff officers noticed that Mr. Janota was visibly intoxicated during his arrest. Id. Mr. Janota was then transported to the Love County Justice Center. Id. ¶ 28. Upon his admission, Mr. Janota and his mother notified several Justice Center employees, including detention officers Stefan Williams and Kara Hurst, and Jail Administrator Crystal Boyd, that he suffered from alcoholism and that he might experience withdrawal symptoms and seizures. Id. ¶¶ 29, 83. Defendants Williams, Hurst, and Boyd were also “directly involved in Mr.

Janota’s admission and personally observed his condition.” Id. ¶ 30. They did not, however, refer Janota for medical evaluation or assessment. Id. ¶ 32. At a later unspecified time, Mr. Janota suffered “withdrawal symptoms” and suffered a seizure. Id. ¶ 33. This seizure ultimately caused him to fall and suffer a traumatic head injury. Id. Williams, Hurst, and Boyd then “personally attended” to Mr. Janota, stood him in an upright position and attempted to move him, and contacted emergency services to transport him to a hospital. Id. ¶¶ 34-36. Case No. 24-CV-326-FAB-GLJ 3

Following Mr. Janota’s injury, Love County Emergency Medical Services (“EMS”) transported him by ambulance to an emergency room at Mercy Hospital Ardmore (“Mercy Ardmore”). Id. ¶ 37. Although Mr. Janota suffered another seizure in transit and “rapidly declin[ed],” the ambulance staff did not turn on the vehicle’s light or sirens. Id. ¶¶ 38-39. Upon his arrival at the emergency room, Mercy Ardmore personnel did not order an immediate head CT scan even though Mr. Janota had “dangerously high blood pressure and tachycardia.” Id. ¶¶ 41-42. Consequently, Mr. Janota remained tachycardic and with high blood pressure for the four hours he was at the hospital. Mercy Ardmore personnel also failed to notice or diagnose abrasions that were indicative of severe brain injury.

Id. ¶¶ 43-44. An ambulance then transported Mr. Janota to the University of Oklahoma Medical Center, where he died from his injuries in the early morning of December 4, 2021. Id. ¶¶ 46-47. On August 16, 2023, Mr. Janota’s Estate, represented by his mother, sued several of the current defendants for their alleged misconduct in the District Court of Love County, Oklahoma. See Case No. CJ-2023-044. The Estate dismissed that lawsuit on February 8, 2024, however, without prosecuting the case or obtaining a summons to serve on defendants. Id. It then refiled this case in this Court on September 13, 2024, (Docket No. 2,) pursuant to Oklahoma’s Saving Statute, 12 Okla. Stat. § 100, which Case No. 24-CV-326-FAB-GLJ 4

allows a plaintiff to refile a claim within one year of dismissal when the claim has otherwise expired under the applicable statute of limitations. (Docket No. 2 at ¶ 19.) Plaintiff Estate has amended its federal complaint three times since then. The operative complaint — the Third Amended Complaint — alleges the following claims: • Against officers Williams and Hurst, and administrator Boyd — (1) a 42 U.S.C. § 1983 claim for their deliberate indifference to Mr. Janota’s Eighth and/or Fourteenth Amendment rights, and (2) a wrongful death claim under Oklahoma law; • Against the Love County Board of County Commissioners, the Love County Jail Trust, and the Love County Sheriff in his official capacity (“Love County Defendants”) — (1) a section 1983 claim for deliberate indifference to Mr. Janota’s Eighth and/or Fourteenth Amendment rights, (2) a violation of his constitutional rights pursuant to Article II, § 9 of the Oklahoma Constitution, (3) a negligence claim pursuant to Oklahoma law, and (4) a wrongful death claim also pursuant to Oklahoma law; • Against the Board of Trustees of The Love County Emergency Medical Services District (“EMS Board”) — (1) a section 1983 claim for deliberate indifference to Mr. Janota’s Eighth and/or Fourteenth Amendment rights, (2) a violation of his constitutional rights pursuant to Article II, § 9 of the Oklahoma Constitution, (3) a negligence claim pursuant to Oklahoma law, and (4) a wrongful death claim pursuant to Oklahoma law; and • Against Mercy Ardmore — (1) a negligence claim and (2) wrongful death claim, both pursuant to Oklahoma law. (Docket No. 109.) Case No. 24-CV-326-FAB-GLJ 5

All of the defendants moved to dismiss the Estate’s claims on various grounds, including failure to state a claim, sovereign immunity, and untimeliness based on the statute of limitations. The magistrate judge found, however, that dismissal was warranted for reasons other than the statute of limitations. And because the Court may dismiss plaintiff’s claims based on failure to state a claim, sovereign immunity, and supplementary jurisdiction grounds, the Court need not review those statute of limitations issues. The Court will explain its reasons for dismissal. STANDARD OF REVIEW After a Report and Recommendation has been issued, “a party may serve and file specific written objections to the proposed findings and recommendations.” Fed. R. Civ. P. 72(b). The Court

“must determine de novo any part of the magistrate judge’s disposition that has been properly objected to. The district judge may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate judge with instructions.” Id.; see also 28 U.S.C. § 636(b)(1). Any objections not properly raised, however, are waived for purposes of review by the Court. Klein v. Harper, 777 F.3d 1144, 1147 (10th Cir. 2015); Silva v. United States, 45 F.4th 1134, 1136 n. 2 (10th Cir. 2022). An objection to a report and recommendation is properly raised if it is both timely and specific. United States Case No. 24-CV-326-FAB-GLJ 6

v. One Parcel of Real Property Known as 2121 E. 30th St., 73 F.3d 1057, 1059 (10th Cir. 1996). An objection is sufficiently specific if it “enables the district judge to focus attention on those issues — factual and legal — that are at the heart of the parties’ dispute.” Id. “In the absence of a proper objection, the district court may review a magistrate judge’s recommendation under any standard it deems appropriate.” Davis v. GEO Grp. Corr., Inc., No. CIV-16-00462-PRW, 2023 WL 2536727, at *1 (W.D. Okla. Mar. 16, 2023) (citing Summers v.

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