Alonzo v. Cain
154 So. 3d 551
La. Ct. App.2014Background
- Thirteen inmates at Louisiana State Penitentiary (Angola) sued after a prison-made trailer lost a wheel and injured passengers; they exhausted the CARP administrative tort grievance process and filed suit in state district court.
- The State raised venue and improper-cumulation (non‑cumulation) dilatory exceptions; the case was transferred from the 19th to the 20th Judicial District after venue was sustained.
- After transfer, the State renewed a dilatory exception arguing the prisoners’ claims were improperly cumulated (multiple plaintiffs in one suit).
- The 20th Judicial District sustained the exception and dismissed all plaintiffs except the first-named plaintiff, Curt Alonzo.
- Plaintiffs appealed, arguing the PLRA non‑cumulation provision applies only to “conditions of confinement” claims and not to prisoner tort (delictual) claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether La. R.S. 15:1184(G) prohibits cumulation of multiple prisoners’ actions, including tort claims | Section 1184(G) applies only to "conditions of confinement" suits and does not bar cumulation of delictual/tort claims | The statute uses the broad term "action," and the PLRA's context (venue for delictual actions, definitions of prisoner suits) shows the non‑cumulation rule applies to all prisoner actions, including tort claims | Court held Section 1184(G) bars cumulating actions by more than one prisoner; only the first‑named plaintiff may proceed; others dismissed |
Key Cases Cited
- Dietz v. Superior Oil Co., 129 So.3d 836 (La. App. 3 Cir. 2013) (standard of review for dilatory exception sustaining improper cumulation is manifest error)
- Pope v. State, 792 So.2d 713 (La. 2001) (discussing CARP’s scope and relation to federal standards)
- McCoy v. Stalder, 770 So.2d 447 (La. App. 1 Cir. 2000) (inmate may not seek review of more than one ARP in the same petition)
- Lightfoot v. Stalder, 727 So.2d 553 (La. App. 1 Cir. 1998) (same principle restricting joinder of multiple inmate ARP claims)
- Dickens v. Louisiana Correctional Institute for Women, 77 So.3d 70 (La. App. 1 Cir. 2011) (clarifying CARP exhaustion requirement and district court jurisdiction for prisoner tort suits)