Meaux v. Public Safety & Corrections
1:19-cv-01014
W.D. La.Feb 23, 2022Background:
- Plaintiff Ben Meaux, an inmate at Raymond Laborde Correctional Center, sued under 42 U.S.C. § 1983 alleging exposure to environmental tobacco smoke (ETS) caused respiratory problems requiring medication.
- Meaux alleges inmates convert smokeless tobacco into a smokable form and that Secretary James LeBlanc toured RLCC, noticed the smoke odor, was informed of the problem, but failed to act.
- Meaux initially named the DOC, LeBlanc, Warden McCain, and others; claims against the DOC and some officials were previously dismissed and the official-capacity damages claim against LeBlanc was dismissed earlier.
- Defendants Warden Marcus Meyers and Secretary LeBlanc moved to dismiss: Meyers arguing Eleventh Amendment immunity to monetary damages; LeBlanc arguing lack of personal involvement for individual liability.
- The magistrate judge recommends granting the motion in part (dismissing monetary damages claim against Meyers in his official capacity) and denying it in part (allowing Meaux’s individual-capacity deliberate-indifference claim against LeBlanc to proceed).
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Meyers can be sued for monetary damages in his official capacity | Meaux added Warden Meyers as an official-capacity defendant seeking damages for ETS exposure | Louisiana has not waived Eleventh Amendment immunity; suits against state officials in their official capacity are suits against the state | Monetary damages claim against Meyers in official capacity barred by the Eleventh Amendment; injunctive/declaratory relief not barred |
| Whether LeBlanc can be held personally liable for ETS exposure (deliberate indifference) | LeBlanc personally toured RLCC, smelled smoke, was informed of nonenforcement, and failed to remedy the risk causing Meaux harm | LeBlanc does not supervise day-to-day RLCC operations and lacks personal involvement | Meaux pleaded sufficient facts to state a plausible individual-capacity claim against LeBlanc; dismissal as to LeBlanc denied |
Key Cases Cited
- Ramming v. United States, 281 F.3d 158 (5th Cir. 2001) (standards for Rule 12(b)(1) jurisdictional review)
- Barrera–Montenegro v. United States, 74 F.3d 657 (5th Cir. 1996) (jurisdictional review principles)
- Hafer v. Melo, 502 U.S. 21 (1991) (official-capacity suits are suits against the state; distinction between official- and individual-capacity suits)
- Cozzo v. Tangipahoa Parish Council–President Government, 279 F.3d 273 (5th Cir. 2002) (Eleventh Amendment limits on suits against states)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989) (official-capacity suits seeking damages are treated as suits against the state)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
- Haines v. Kerner, 404 U.S. 519 (1972) (liberal construction of pro se pleadings)
- Johnson v. Atkins, 999 F.2d 99 (5th Cir. 1993) (pro se litigant must still plead facts supporting a claim)
- Paterson v. Weinberger, 644 F.2d 521 (5th Cir. 1981) (take allegations as true at pleading stage)
- Black v. Concordia Par. Det. Ctr., [citation="607 F. App'x 440"] (5th Cir. 2015) (reversing dismissal of ETS claim where plaintiff alleged administrative complaints and knowledge by LeBlanc)
- Rochon v. City of Angola, 122 F.3d 319 (5th Cir. 1997) (deliberate indifference standard)