Winbush v. Louisiana

CourtDistrict Court, W.D. Louisiana
DecidedJuly 11, 2025
Docket5:24-cv-00669
StatusUnknown

This text of Winbush v. Louisiana (Winbush v. Louisiana) 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
Winbush v. Louisiana, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF LOUISIANA

SHREVEPORT DIVISION

JAVONPE’ D. WINBUSH CIVIL ACTION NO. 24-669-P

VERSUS JUDGE HICKS

STATE OF LOUISIANA, 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 in forma pauperis by pro se plaintiff Javonpe’ D. Winbush (“Plaintiff”), pursuant to 42 U.S.C. § 1983. This complaint was received and filed in this court on May 20, 2024. On August 16, 2024, this complaint was stricken from the record and on September 6, 2024, it was reinstated. Plaintiff is incarcerated at the David Wade Correctional Center in Homer, Louisiana. He names the State of Louisiana, Detective Henry, Attorney Katherine Ferguson, and Judge Ramona Emanuel as defendants. Plaintiff claims that on February 5, 2021, Detective Henry violated his Fifth Amendment rights. He claims Detective Henry contacted his mother who was his legal guardian about his current location, but did not inform his mother that he was being arrested and interrogated. He claims Detective Henry failed to notify his mother to be present at the station during the interrogation. He claims Detective Henry had his cousin present to consent to the interrogation and waive his juvenile rights, instead of his mother. Plaintiff argues his cousin was not his legal guardian.

Plaintiff claims his guilty plea was involuntary because he received ineffective assistance of counsel. He claims he informed his counsel Katherine Ferguson that his legal guardian was not present during his interrogation. He claims Ferguson failed to investigate whether his incriminating statement was inadmissible. He claims Ferguson wrote in her notes that he asked for a deal for the armed robbery charge. He claims he never asked

Ferguson about a deal for the armed robbery charge. Plaintiff claims he informed Ferguson that he was under the influence of drugs during his interrogation. He claims Ferguson failed to file a motion to suppress his statement. He claims Ferguson’s notes state that he informed her that his juvenile interrogation form had no signature. He claims he never informed Ferguson that his juvenile interrogation form had no signature. He claims

Ferguson wrote in her notes that because he pleaded guilty, she could not file a motion to suppress his statement, the evidence rules did not apply, and an adult was present. He also claims Ferguson failed to object when Detective Henry stated during questioning that he did not ask Plaintiff if he was under the influence. He claims Ferguson failed to argue and inform him that he was being subjected to double jeopardy. Plaintiff argues that Ferguson

violated his Sixth Amendment rights. Plaintiff claims that his convictions and sentences for armed robbery and principal to manslaughter violate his Fifth Amendment right against double jeopardy. He claims the

Page 2 of 9 same evidence was used to support both convictions. Judge Ramona Emanuel is the judge who sentenced Plaintiff. He also claims his Fourteenth Amendment right to due process

was violated when the State used his incriminating statement against him at his sentencing. Plaintiff seeks to have the State of Louisiana reduce his sentence, release him from jail, or give him funds. LAW AND ANALYSIS Heck Claim

Plaintiff claims he was wrongly convicted and sentenced for armed robbery and principal to manslaughter because of the actions of Defendants. Plaintiff is seeking monetary damages for his allegedly unconstitutional convictions and sentences. 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 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 Page 3 of 9 demonstrate that his conviction or sentence had been invalidated. When a claim comes within the parameters of the Heck teachings, it is not cognizable under 42 U.S.C. § 1983 so long as the validity of the conviction or sentence has not been called into question as

defined therein, which requires dismissal of claims not meeting its preconditions for suit. See Johnson v. McElveen, 101 F.3d 423, 424 (5th Cir. 1996). Plaintiff is seeking monetary damages for civil rights violations under Section 1983; therefore, he must prove his convictions and/or sentences have been invalidated. He has not met this precondition, and his claims must be dismissed until such time that he can

demonstrate that his convictions and/or sentences have been invalidated. Attorney Katherine Ferguson Plaintiff claims Attorney Katherine Ferguson provided him with ineffective assistance of counsel and violated his Sixth Amendment rights. Plaintiff does not specifically allege that Ferguson acted under color of state law.

Section 1983 prescribes redress for conduct by any person who, under color of state law, acts to deprive another person of any right, privilege or immunity secured by the Constitution and laws of the United States. 42 U.S.C. § 1983. A plaintiff in a civil rights suit must show that the conduct complained of was committed by a person acting under color of state law. Neither privately obtained nor court appointed defense attorneys act

under color of state law for purposes of Section 1983. Both a retained and a court appointed attorney serve their client, the accused; they do not serve the state. They serve a private function for their client that follows from the Page 4 of 9 very nature of the attorney-client relationship and for which no state office or authority are needed. Hence, neither a retained nor a court appointed attorney acts under color of state law and cannot be held liable under Section 1983. See Polk County v. Dodson, 454 U.S.

312 (1981); Ellison v. DeLa Rosa, 685 F.2d 959, 960 (5th Cir. 1982) (citing Polk County, supra); United States ex rel. Simmons v. Zibilich, 542 F.2d 259, 261 (5th Cir. 1976); Nelson v. Stratton, 469 F.2d 1155 (5th Cir. 1972); Richardson v.

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