Chaney v. Jones, 2:15-cv-02808

Darian Chaney filed a § 1983 and state tort complaint arising from a traffic stop, chase, and alleged police brutality in Vernon Parish, naming the City of Leesville and officers Landon Dowden and Jacqueline Jones.
Chaney's counsel moved to withdraw after Chaney terminated representation; the court granted withdrawal and Chaney proceeded pro se.
After proceeding pro se, Chaney sent multiple letters claiming he was not suing the individual officers but only the City; later he indicated he intended to sue the officers individually.
Defendants Dowden and Jones moved for summary judgment arguing Chaney had repeatedly stated he did not intend to sue them (i.e., they were wrongly named).
The magistrate judge reviewed the summary judgment standard and determined the officers were proper defendants for individual-capacity § 1983 claims given Chaney’s allegations of action under color of law and personal involvement.
Recommendation: deny the officers’ summary judgment motions because defendants failed to show they were wrongly named and Chaney’s subsequent statements assert claims against them.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers are entitled to summary judgment because plaintiff repeatedly stated he was not suing them	Chaney initially said he was not suing the individual officers but later confirmed he intended to sue them individually	Dowden and Jones contend Chaney’s prior statements show they were wrongly named and thus summary judgment is proper	Denied — officers not entitled to summary judgment; plaintiff’s later statements and complaint support individual-capacity claims
Whether the officers are proper § 1983 defendants	Chaney alleges officers acted under color of state law and personally participated in alleged violations	Officers argue wrong-party naming based on plaintiff’s letters	Held proper parties — factual allegations support individual liability under § 1983

Celotex Corp. v. Catrett, 106 S. Ct. 2548 (summary judgment burden shifting standard)
Tubacex, Inc. v. M/V Risan, 45 F.3d 951 (movant’s initial burden on summary judgment)
Anderson v. Liberty Lobby, Inc., 106 S. Ct. 2505 (genuine issue and significant probative evidence standard)
Tolan v. Cotton, 134 S. Ct. 1861 (view evidence in light most favorable to nonmovant)
Reeves v. Sanderson Plumbing Prods., Inc., 120 S. Ct. 2097 (court may not weigh evidence or make credibility determinations at summary judgment)
State Farm Life Ins. Co. v. Gutterman, 896 F.2d 116 (nonmovant must submit significant probative evidence)
Nelson v. Int’l Paint Co., Inc., 734 F.2d 1084 (summary judgment appropriate when plaintiff names wrong party)
James v. Texas Collin County, 535 F.3d 365 (individual-capacity § 1983 liability standard)
Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415 (objections to magistrate recommendations and consequences of failure to object)