Young v. LeBlanc
3:23-cv-00681
M.D. La.Mar 11, 2025Background
- Robert Young, a former pretrial detainee at Catahoula Correctional Center (CCC), sued several officials, including James LeBlanc (Secretary, DPSC) and Seth Smith (Chief of Operations, DPSC), under 42 U.S.C. §1983 for alleged Eighth and Fourteenth Amendment violations related to an inmate attack.
- Plaintiff alleges DPSC officials were negligent and responsible for local facility oversight failures, seeking declaratory and injunctive relief, damages, and attorneys’ fees.
- Plaintiff served extensive discovery requests (RFPs) seeking documents on policies, incident reports, jail guidelines, audits, contracts, and records about both CCC and other Louisiana facilities.
- Defendants objected to many RFPs as overbroad, irrelevant, or duplicative, referencing prior production from a similar case, Murray v. LeBlanc, and in some cases provided additional documents or stated they had no further responsive records.
- Procedurally, the plaintiff moved to compel further discovery responses. The court noted plaintiff’s imperfect compliance with Rule 37’s requirement for a good faith meet-and-confer, but declined to deny the motion solely for that reason.
- The court’s decision evaluates whether the discovery requests were relevant and proportional, often narrowing requests to focus only on the CCC and the relevant period of Young’s detention.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of Basic Jail Guidelines (BJG) discovery | All BJG drafts/revisions are relevant to DPSC oversight liability | BJG not relevant to pretrial detainees; requests are overbroad and cover excessive time | BJG relevant but requests overbroad; no further response compelled |
| Contracts with local facilities | Contracts show DPSC oversight, needed for Young’s claims | Already produced, not relevant to pretrial detainees, overbroad, no further responsive docs | Request overbroad; no further response compelled |
| Incident/contraband reports for all Louisiana facilities | Show policy/practice of inadequate supervision | Overbroad, not CCC-specific, documents largely already produced | Overbroad for facilities other than CCC; compelled response only as tailored to CCC/time |
| Requests for CCC-specific audits, billing, personnel info | Relevant to claims of facility conditions and DPSC oversight | Some provided, rest not in possession, overbroad if seeking info about others/time frames | Some requests narrowed (CCC, relevant time), compelled as to those; otherwise denied |
Key Cases Cited
- In re United States, 864 F.2d 1153 (5th Cir. 1989) (insufficient or untimely objections to discovery may be deemed waived)
- Crittindon v. LeBlanc, 37 F.4th 177 (5th Cir. 2022) (DPSC officials have power and responsibility over local jails housing state prisoners)
