Thomas v. East Carroll Parish

CourtDistrict Court, W.D. Louisiana
DecidedJuly 24, 2025
Docket3:25-cv-00574
StatusUnknown

This text of Thomas v. East Carroll Parish (Thomas v. East Carroll Parish) 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
Thomas v. East Carroll Parish, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA

MONROE DIVISION

GERMANY GERMAINE THOMAS CIVIL ACTION NO. 25-0574

SECTION P VS. JUDGE JERRY EDWARDS, JR.

EAST CARROLL PARISH SHERIFF'S MAG. JUDGE KAYLA D. MCCLUSKY OFFICE, ET AL.

REPORT AND RECOMMENDATION

Plaintiff Germany Germaine Thomas, a prisoner at East Carroll Detention Center ("ECDC") proceeding pro se and in forma pauperis, filed this proceeding on approximately April 28, 2025, under 42 U.S.C. § 1983. He names the following Defendants: East Carroll Parish Sheriff's Office, "East Carroll Det. Ctr./Medical Staff," and “everybody that works on the chow line.”1 For reasons that follow, the Court should dismiss Plaintiff’s claims. Background

Plaintiff was incarcerated at ECDC beginning March or April 2025. [doc. # 1, p. 3]. He is diabetic and claims that as of the filing of his initial pleading in April 2025, he is (1) "being refused diabetic snacks" when his sugar level is low and (2) forced to eat "regular inmate diet trays and [is] not receiving a diabetic tray" because the facility lacks a dietician. Id.

1 This matter has been referred to the undersigned for review, report, and recommendation under 28 U.S.C. § 636, and the standing orders of the Court. In an amended pleading, Plaintiff faults “everybody that works on the chow line” because they “don’t have diabetic trays” and obtain the food they serve “from Unit 3.” [doc. # 8, p. 1]. For relief, Plaintiff seeks $500,000.00. [doc. # 1, p. 4].

Law and Analysis

1. Preliminary Screening

Plaintiff is a prisoner who has been permitted to proceed in forma pauperis. As a prisoner seeking redress from an officer or employee of a governmental entity, his complaint is subject to preliminary screening pursuant to 28 U.S.C. § 1915A.2 See Martin v. Scott, 156 F.3d 578, 579-80 (5th Cir. 1998) (per curiam). Because he is proceeding in forma pauperis, his Complaint is also subject to screening under § 1915(e)(2). Both § 1915(e)(2)(B) and § 1915A(b) provide for sua sponte dismissal of the complaint, or any portion thereof, if the Court finds it is frivolous or malicious, if it fails to state a claim on which relief may be granted, or if it seeks monetary relief against a defendant who is immune from such relief. A complaint is frivolous when it “lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). A claim lacks an arguable basis in law when it is “based on an indisputably meritless legal theory.” Id. at 327. Courts are also afforded the unusual power to pierce the veil of the factual allegations and dismiss those claims whose factual contentions are clearly baseless. Id. A complaint fails to state a claim on which relief may be granted when it fails to plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly,

2 Under 28 U.S.C. § 1915(h), “‘prisoner’ means any person incarcerated or detained in any facility who is accused of, convicted of, sentenced for, or adjudicated delinquent for, violations of criminal law or the terms and conditions of parole, probation, pretrial release, or diversionary program.” 550 U.S. 544, 570 (2007); accord Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A claim is facially plausible when it contains sufficient factual content for the court “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 570). Plausibility does not equate to possibility or probability; it lies

somewhere in between. Id. Plausibility simply calls for enough factual allegations to raise a reasonable expectation that discovery will reveal evidence to support the elements of the claim. Twombly, 550 U.S. at 556. Assessing whether a complaint states a plausible claim for relief is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, supra. A well-pled complaint may proceed even if it strikes the court that actual proof of the asserted facts is improbable and that recovery is unlikely. Twombly, supra. In making this determination, the court must assume that all the plaintiff’s factual allegations are true. Bradley v. Puckett, 157 F.3d 1022, 1025 (5th Cir. 1998). However, the same presumption does not extend to legal conclusions. Iqbal, supra. A pleading comprised of

“labels and conclusions” or “a formulaic recitation of the elements of a cause of action” does not satisfy Rule 8. Id. A complaint fails to state a claim where its factual allegations do not “raise a right to relief above the speculative level.” Montoya v. FedEx Ground Package Sys., Inc., 614 F.3d 145, 148 (5th Cir. 2010) (quoting Twombly, 550 U.S. at 555). “[U]nadorned, the-defendant unlawfully-harmed-me accusation[s]” will not suffice. Iqbal, 556 U.S. at 677. “[P]laintiffs must allege facts that support the elements of the cause of action in order to make out a valid claim.” City of Clinton, Ark. v. Pilgrim’s Pride Corp, 632 F.3d 148, 152-53 (5th Cir. 2010). Courts are “not free to speculate that the plaintiff ‘might’ be able to state a claim if given yet another opportunity to add more facts to the complaint.” Macias v. Raul A. (Unknown) Badge No. 153, 23 F.3d 94, 97 (5th Cir. 1994). A hearing need not be conducted for every pro se complaint. Wilson v. Barrientos, 926 F.2d 480, 483 n.4 (5th Cir. 1991). A district court may dismiss a prisoner’s civil rights complaint as frivolous based upon the complaint and exhibits alone. Green v. McKaskle, 788

F.2d 1116, 1120 (5th Cir. 1986). “To state a section 1983 claim, a plaintiff must (1) allege a violation of a right secured by the Constitution or laws of the United States and (2) demonstrate that the alleged deprivation was committed by a person acting under color of state law.” Whitley v. Hanna, 726 F.3d 631, 638 (5th Cir. 2013) (internal quotation marks omitted). Consistent with the standard above, a “[S]ection 1983 complaint must state specific facts, not simply legal and constitutional conclusions.” Fee v. Herndon, 900 F.2d 804, 807 (5th Cir. 1990). 2. Defendants Unamenable to Suit As above, Plaintiff names the following entities as Defendants: East Carroll Parish Sheriff's Office, "East Carroll Det. Ctr./Medical Staff," and “everybody that works on the chow

line.” Federal Rule of Civil Procedure

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Related

Macias v. Raul A. (Unknown), Badge No. 153
23 F.3d 94 (Fifth Circuit, 1994)
Martin v. Scott
156 F.3d 578 (Fifth Circuit, 1998)
Bradley v. Puckett
157 F.3d 1022 (Fifth Circuit, 1998)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Montoya v. FedEx Ground Package System, Inc.
614 F.3d 145 (Fifth Circuit, 2010)
City of Clinton, Ark. v. Pilgrim's Pride Corp.
632 F.3d 148 (Fifth Circuit, 2010)
John Calvin Thompson v. L.A. Steele
709 F.2d 381 (Fifth Circuit, 1983)
Natasha Whitley v. John Hanna
726 F.3d 631 (Fifth Circuit, 2013)
Larry Alderson v. Concordia Parish Corrtl Facil, e
848 F.3d 415 (Fifth Circuit, 2017)

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Bluebook (online)
Thomas v. East Carroll Parish, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-v-east-carroll-parish-lawd-2025.