Lincoln v. United States Homeland Prisoner Transport LLC
5:25-cv-00343
M.D. Fla.May 23, 2025Background
- Douglas Lincoln, Jr. (plaintiff), filed suit against Ellis County, Texas, and United States Homeland Prisoner Transport, LLC, alleging constitutional and other violations related to his transport as a prisoner.
- The plaintiff asserted claims under 42 U.S.C. § 1983 and referenced violations of federal transportation laws and Texas law.
- The magistrate judge recommended that all claims against Ellis County be dismissed with prejudice for failure to identify an official policy/custom or link to a policymaker and for lack of a waiver of governmental immunity for state claims.
- The judge also found the plaintiff's federal transportation law and Texas Code of Criminal Procedure claims did not provide a valid private cause of action.
- The court decided to sever and transfer the remaining claims against United States Homeland Prisoner Transport, LLC, to the Middle District of Florida pursuant to 28 U.S.C. § 1404(a).
- No objections were filed to the magistrate judge’s recommendations, and the court denied further leave to amend, ruling that any amendment would be futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| § 1983 municipal liability against Ellis County | County liable under § 1983 policies | No identified policy/custom, no link to policymaker | Dismissed: No policy or custom or policymaker alleged |
| State tort claims against Ellis County | State claims actionable | Governmental immunity not waived | Dismissed: No waiver of immunity |
| Claims under federal transportation/Texas criminal procedure | Violation of such laws entitles relief | No private cause of action exists | Dismissed: No private cause of action |
| Motion to amend pleadings | Opportunity to fix deficiencies | Plaintiff already amended, amendment futile | Denied: Amendment would be futile, would delay |
| Venue for claims against Homeland Transport | Claims can remain in Texas | Should be transferred | Transferred: Claims moved to Middle District of Florida |
Key Cases Cited
- Foman v. Davis, 371 U.S. 178 (discusses district court's discretion re: amending pleadings)
- Howard v. King, 707 F.2d 215 (standard for certification of frivolous appeals)
- Baugh v. Taylor, 117 F.3d 197 (procedures for proceeding in forma pauperis on appeal)
- Legate v. Livingston, 822 F.3d 207 (futility as basis for denying leave to amend)