Vallejo v. Prator

CourtDistrict Court, W.D. Louisiana
DecidedDecember 13, 2024
Docket5:23-cv-01580
StatusUnknown

This text of Vallejo v. Prator (Vallejo v. Prator) 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
Vallejo v. Prator, (W.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF LOUISIANA

SHREVEPORT DIVISION

JOE THOMAS VALLEJO CIVIL ACTION NO. 23-1580-P

VERSUS JUDGE DOUGHTY

STEVEN PRATOR, ET AL. MAGISTRATE JUDGE HORNSBY

REPORT AND RECOMMENDATION In accordance with the standing order of this court, this matter was referred to the undersigned Magistrate Judge for review, report and recommendation. STATEMENT OF CLAIM Before the court is a civil rights complaint filed by pro se plaintiff Joe Thomas Vallejo (“Plaintiff”), pursuant to 42 U.S.C. § 1983. Plaintiff is a transgender female. This complaint was received and filed in this court on November 2, 2023. Plaintiff is currently incarcerated at the Bossier Medium Correctional Center in Plain Dealing, Louisiana. Plaintiff names Steven Prator, Rick Farris, Ms. Fredieu, James LeBlanc, and Jane and John Does as Defendants.1 On April 25, 2022, Plaintiff reported to Parole Agent Thomas. He asked Agent Thomas for assistance because he was homeless and needed shelter, food, clothing, and valid identification documents. He claims Agent Thomas told him that he was ineligible for assistance because it was the end of the month. He claims Agent Thomas

1 Plaintiff also states claims in his complaint regarding the policies of the Caddo Correctional Center, retaliation, denial of access to the courts, and the policies of the Office of Probation and Parole which will be addressed in a separate Memorandum Order. discriminated against him because of his sexual orientation. He claims Agent Thomas had issues with him at his initial visit and asked his supervisors to remove him from his case. Plaintiff was then assigned to a female parole agent. On June 28, 2022, Plaintiff was arrested by Shreveport Police Officers (John Does 1-5) who were conducting a prostitution sting. Plaintiff claims he was a displaced,

homeless, transgender female parolee at the time of his arrest. He claims it was his first arrest for misdemeanor prostitution, but the charge was transferred to the felony division. Plaintiff was transferred to the Shreveport City Jail. He claims he was treated unreasonably by two African American females (Jane Does 1 and 2). Plaintiff was then transported to the Caddo Correctional Center to be booked for the prostitution charge and

parole violation hold. Plaintiff claims that on July 16, 2022, Probation and Parole contacted him at the Caddo Correctional Center. He claims he was informed of his charges and misled by Parole Officer John Doe to violate himself by waiving his right to a parole revocation hearing. He claims the Parole Officer told him that as a felony offender, he would be

convicted for the felony charge and not the misdemeanor charge. He claims his parole was revoked. Plaintiff claims that on September 17, 2022, he appeared in court before Judge Ramona Emanuel and was offered a plea deal to the misdemeanor offense of prostitution.

Page 2 of 9 Plaintiff was transferred from the Caddo Correctional Center to the Richland Parish Correctional Center. He claims his property, canteen, and legal documents and books were not transferred with him. Accordingly, Plaintiff seeks injunctive relief, monetary and punitive damages, and any other relief to which he is entitled.

LAW AND ANALYSIS Prescription In Wilson v. Garcia, 471 U.S. 261 (1985), the Court articulated the guidelines to be used in determining what prescriptive period should apply to Section 1983 claims. The Court determined "§ 1983 claims are best characterized as personal injury actions" and

the forum state's statute of limitations applicable to such claims should be used. Id. at 280. In Gates v. Spinks, 771 F.2d 916 (5th Cir. 1985), the Fifth Circuit Court of Appeals phrased the test as: "The state statute governing the general tort remedy for personal injuries should apply to 1983 actions . . ." Gates, 771 F.2d at 919. The Louisiana Civil Code provides a general prescriptive statute that governs tort

actions. The article subjects delictual actions to a liberative prescription of one year. See La. C.C. art. 3492.2 The Fifth Circuit qualified this prescriptive period, however, when it held that "a section 1983 action accrues and the statute of limitations begins to run when

2 La. C.C. art. 3492 was repealed by Acts 2024, No. 423, § 2, eff. July 1, 2024. Section 3 of Acts 2024 provides “The provisions of the Act shall be given prospective application only and shall apply to delictual actions after the effective date of this Act.” Thus, La. C.C. art. 3492 is still applicable as to this complaint.

Page 3 of 9 the plaintiff knows or has reason to know of the injury which is the basis for the action." Watts v. Graves, 720 F.2d 1416, 1417 (5th Cir. 1983). Plaintiff claims his civil rights were violated by Parole Agent Thomas on April 25, 2022. Thus, prescription began to run as to these claims on April 25, 2022. He claims he was arrested by John Does 1-5 on June 28, 2022 during a prostitution sting. Thus, prescription began to run as to any arrest claims on June 28, 2022. He claims he was

treated unreasonably at the Shreveport City Jail on June 28, 2022 by Jane Does 1 and 2. Thus, prescription began to ran as to these claims on June 28, 2022. The above entitled and numbered complaint was not signed by Plaintiff until October 21, 2023, and it was not filed by the Clerk of Court until November 2, 2023. Plaintiff’s claims against Parole Agent Thomas, John Does 1-5, and Jane Does 1-2 are therefore prescribed.

Accordingly, Plaintiff’s claims against Agent Thomas, John Does 1-5, and Jane Does 1-2 should be dismissed as frivolous. Heck Claim Plaintiff claims his parole was wrongly revoked because he was misled by Parole Officer John Doe. Plaintiff is seeking monetary damages and injunctive relief for an

allegedly unconstitutional parole revocation. The United States Supreme Court held that in order to recover monetary compensation for an allegedly unconstitutional conviction or sentence or for “harm caused by actions whose unlawfulness would render a conviction or sentence invalid,” a prisoner must show that the conviction or sentence has been “reversed on direct appeal, expunged by executive order, declared invalid by a state

Page 4 of 9 tribunal authorized to make such determination, or called into question by a federal court's issuance of a writ of habeas.” Heck v. Humphrey, 512 U.S. 477, 486–87, 114 S.Ct. 2364, 2372 (1994). Courts have also extended the holding in Heck to claims seeking injunctive or declaratory relief pursuant to 42 U.S.C. § 1983. See Edwards v. Balisok, 520 U.S. 641,648, 117 S.Ct. 1584, 1589, 137 L.Ed.2d 906 (1997); Clark v. Stalder, 154 F.3d 186, 190-91 (5th Cir. 1998). Heck involved a civil rights claim brought by a state prisoner. The

Court dismissed the Section 1983 suit until plaintiff could demonstrate that his conviction or sentence had been invalidated. The holding in Heck has been extended to parole revocation proceedings. Littles v. Bd. of Pardons and Paroles Div., 68 F.3d 122, 123 (5th Cir. 1995). When a claim comes within the parameters of the Heck teachings, it is not

cognizable under 42 U.S.C.

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

Related

Booker v. Koonce
2 F.3d 114 (Fifth Circuit, 1993)
Littles v. Board of Pardons & Paroles Division
68 F.3d 122 (Fifth Circuit, 1995)
Baker v. McCollan
443 U.S. 137 (Supreme Court, 1979)
Parratt v. Taylor
451 U.S. 527 (Supreme Court, 1981)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Wilson v. Garcia
471 U.S. 261 (Supreme Court, 1985)
Daniels v. Williams
474 U.S. 327 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Edwards v. Balisok
520 U.S. 641 (Supreme Court, 1997)
Wallace Watts v. Odom Graves, Sheriff
720 F.2d 1416 (Fifth Circuit, 1983)
Eddie Lee Marshall v. Joe Lee Norwood
741 F.2d 761 (Fifth Circuit, 1984)
Mrs. Peggy Gates v. Dr. Sam Spinks
771 F.2d 916 (Fifth Circuit, 1985)
Cleveland Hicks, Jr. v. Jack M. Garner, Etc.
69 F.3d 22 (Fifth Circuit, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Vallejo v. Prator, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vallejo-v-prator-lawd-2024.