Angela Jones v. Board of Suprs Univ of LA Sys
702 F. App'x 205
| 5th Cir. | 2017Background
- Angela Jones sued the University of Louisiana System and campus officers in a federal civil-rights employment action and settled for $75,000 in March 2016.
- Jones moved under Fed. R. Civ. P. 67 to deposit the settlement proceeds in the district court’s registry; the district court granted that motion and defendants deposited $75,000.
- Michael Prescott, who previously had obtained a $175,000 default judgment against Jones in Louisiana state court and served a writ of fieri facias/garnishment on the University in November 2015, objected that the writ attached the settlement funds.
- The district court found the writ did not seize the settlement funds because the University did not possess the $75,000 (the debt arose later), released attorney’s fees and the remaining funds to Jones, and denied Prescott’s motions to return funds or stay disbursement.
- Prescott appealed the September 23 order releasing funds and the September 26 denial of a stay; the Fifth Circuit treated the appeal as also encompassing the May 12 Rule 67 deposit order and reviewed discretion, abstention (Younger), and Rule 62 stay issues.
Issues
| Issue | Plaintiff's Argument (Jones) | Defendant's Argument (Prescott) | Held |
|---|---|---|---|
| Whether district court abused discretion in allowing Rule 67 deposit | Rule 67 deposit was proper to have the court determine ownership and disburse funds | Deposit was improvidently granted; court should not have taken funds into registry | Affirmed: Prescott failed to adequately brief authority; deposit was within district court discretion |
| Whether federal court should have abstained under Younger | No injunction against state court; federal court merely determined ownership of funds | Order to deposit/disburse interfered with state-court writ execution and required Younger abstention | Affirmed: Younger inapplicable—state defamation case not in a Younger category and federal case sought only monetary relief |
| Whether the district court’s disbursement order was subject to automatic stay under Rule 62(a) | Rule 62 did not apply because disbursement order was not a "judgment" | Rule 62(a) automatic stay should have applied to prevent disbursement pending appeal | Court erred in characterizing order but any error harmless because Prescott showed no prejudice; judgment affirmed |
| Appellate jurisdiction over May 12 order | N/A (Jones responded on merits) | Prescott’s notice did not expressly list the May 12 order | Appeal treated as encompassing May 12 order because it’s related to appealed orders and no prejudice to Jones; appellate jurisdiction proper |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (1971) (establishes federal abstention to avoid interfering with certain state proceedings)
- Sprint Commc’n, Inc. v. Jacobs, 134 S. Ct. 584 (2013) (frames three categories of state proceedings triggering Younger abstention)
- In re Craig’s Stores of Texas, Inc., 402 F.3d 522 (5th Cir. 2005) (describing purpose and district-court discretion under Fed. R. Civ. P. 67)
- Cajun Elec. Power Co-op., Inc. v. Riley Stoker Corp., 901 F.2d 441 (5th Cir. 1990) (Rule 67 relief is committed to district court’s discretion)
- Alexander v. Ieyoub, 62 F.3d 709 (5th Cir. 1995) (standard of review for abstention decisions)
- Google, Inc. v. Hood, 822 F.3d 212 (5th Cir. 2016) (Younger applies to injunctive and declaratory relief but not to actions seeking only damages)