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Crawford v. Caddo Parish Corners Office

United States District Court, W.D. Louisiana, Shreveport Division

February 25, 2019

RODRICUS CRAWFORD
v.
CADDO PARISH CORONER'S OFFICE, ET AL.

          HORNSBY MAGISTRATE JUDGE

          MEMORANDUM RULING

          ELIZABETH E. FOOTE JUDGE

         Now before the Court are two Motions to Dismiss for Failure to State a Claim Upon Which Relief can be Granted, pursuant to Federal Rule of Civil Procedure 12(b)(6). The first motion was filed by Defendants James Stewart, Dale Cox, and the Caddo Parish District Attorney's Office. [Record Document 16]. This motion is opposed. [Record Document 29]. For the reasons discussed below, the motion to dismiss [Record Document 16] is GRANTED.

         The second motion to dismiss was filed by Defendant Todd G. Thoma and the Caddo Parish Coroner's Office. [Record Document 18]. Alternatively, Thoma and the Caddo Parish Coroner's Office move for a more definite statement pursuant to Federal Rule of Civil Procedure 12(e). This motion is opposed. [Record Document 28]. For the reasons discussed below, the motion to dismiss [Record Document 18] is GRANTED.

         Also before the Court is a Motion to Dismiss Penalty, Punitive, or Exemplary Damages filed by the Caddo Parish Coroner's Office, the Caddo Parish District Attorney's Office, Cox, Stewart, and Thoma. [Record Document 15]. This motion is opposed. [Record Document 30]. For the reasons discussed below, the motion to dismiss penalty, punitive, or exemplary damages [Record Document 15] is GRANTED.

         FACTUAL BACKGROUND

         This case arises out of the arrest, prosecution, and conviction of Rodricus Crawford ("Plaintiff) for the murder of his son, Roderius Lott. Roderius died on February 16, 2012. Record Document 1, ¶ 16. Authorities interrogated Plaintiff about Roderius's death and on February 24, 2012, he was arrested and subsequently charged with first degree murder. Id. at ¶ 38. Plaintiff was convicted of first degree murder on November 12, 2013, in the First Judicial District Court, Caddo Parish, and was sentenced to death on November 13, 2013. Id. at ¶ 75; State v. Crawford, 218 So.2d 13 (La. 11/16/16).[1] Defendant Dale Cox ("Cox") prosecuted Plaintiff and was the acting District Attorney of Caddo Parish at the time. Id. at ¶s 12 & 63. On November 6, 2016, the Louisiana Supreme Court reversed Plaintiffs conviction and remanded his case for a new trial. Id. at ¶ 75. He was released on November 22, 2016, after posting a $50, 000 bond. Id. Defendant James Stewart ("Stewart"), the current District Attorney of Caddo Parish, dismissed the charges against Plaintiff on April 17, 2017. Id.

         Plaintiff filed the instant lawsuit under Title 42 U.S.C. § 1983 on behalf of himself and his minor child Khasiah Crawford, [2] against the Caddo Parish Coroner's Office; Coroner Todd G. Thoma; James Traylor, M.D.; the Caddo Parish District Attorney's Office; James Stewart, Caddo Parish District Attorney; the Shreveport Fire Department; Sharon Sullivan; Daniel Mars; Dale Cox; ninety-nine "J. Does" that Plaintiff alleges work for Caddo Parish 911 or the Shreveport Police Department; and ten unnamed insurance companies. Record Document 1, p. 1. Plaintiff claims that his prosecution was illegally based on race and religion, and a complete indifference to the evidence. Id. According to Plaintiff, his prosecution and conviction were driven by Caddo Parish's well-known history of racism and the arbitrary application of the death penalty. Id. at 2. Plaintiff asserts that Defendants are liable to him under § 1983 for violations of his Sixth and Fourteenth Amendment rights, as well as the state law torts of intentional infliction of emotional distress and tortious interference in a parent-child relationship. Id. at ¶s 81-106. Finally, Plaintiff brings a direct action under state law against the insurance companies of Defendants. Id. at ¶ 108.

         The Court now turns to the facts giving rise to Plaintiffs alleged causes of action. On the morning of February 16, 2012, an ambulance was summoned to a house in Shreveport, Louisiana where Plaintiff and his infant son Roderius, along with several other family members, were staying. Id. at ¶s 16 & 20. According to the complaint, Roderius had been suffering from pneumonia in all five lobes of his lungs and the bacteria had entered his blood stream, causing septic shock and death. Id. at ¶ 16. The family called an ambulance because Plaintiff, who was sharing a fold-out couch with Roderius, had awakened to find that Roderius was not breathing. Id. at ¶s 19 & 21. Plaintiff alleges that the 911 dispatchers sent out police along with a fire department ambulance because they suspected foul play based on the primarily African-American neighborhood in which the house was located and the number of people in the house.[3] Id. at ¶ 23.

         One of the paramedics who arrived on the scene, Defendant Sharon Sullivan[4] ("Sullivan"), examined Roderius's body and suspected foul play based on fluid[5] draining from the child's nose. Id. at ¶ 27. Sullivan also claimed to observe bruises on the child's buttocks and petechiae in his eyes. Id. Another paramedic, Defendant Daniel Mars ("Mars"), spoke to Plaintiff and claimed that Plaintiff told him that Roderius had fallen off a bed. Id. at ¶ 28. Mars asked the ambulance driver to take them to the hospital because he claimed "the situation was getting kind of violent." Id. at ¶ 29. The Shreveport Police Department arrived shortly thereafter. Id. at ¶ 31. Upon arrival, officers placed Plaintiff in the back of a police cruiser, detained him for over an hour, and then took him to the police station for interrogation. Id. at ¶ 32.

         Defendant Todd G. Thoma ("Thoma"), the elected Coroner of Caddo Parish, was summoned to the emergency room to examine the body. Id. at ¶ 33. Thoma determined that the cause of death was suffocation from smothering and that the death was a homicide. Id. Defendant James Traylor, MD ("Traylor"), [6] a forensic pathologist, contracted with Defendant Caddo Parish Coroner's Office to perform an autopsy on Roderius. Id. at ¶ 34. Traylor incised the skin on Roderius's buttocks and scalp and found hemorrhages that were not visible to the naked eye. Id. He determined that the injuries were a result of child abuse and decided that, combined with the contusions on Roderius's lips, the death was "more likely than not" a smothering. Id. Traylor did not take tissue samples from the buttocks, scalp, or lips that would have revealed the timing of those injuries. Id. at ¶ 35. After announcing that the death was a homicide, Traylor discovered that Roderius had pneumonia in all five lobes of his lungs and that his blood culture tested positive for alpha hemolytic streptococcus bacteria, but Traylor did not order further testing to determine if the positive blood culture was the result of sepsis. Id. at ¶ 36.

         The Court will now address Cox, Stewart, and the Caddo Parish District Attorney's Office's Motion to Dismiss [Record Document 16], the Caddo Parish Coroner's Office and Thoma's Motion to Dismiss [Record Document 18], and Cox, Stewart, the Caddo Parish District Attorney's Office, the Caddo Parish Coroner's Office, and Thoma's Motion to Dismiss Penalty, Punitive, or Exemplary Damages [Record Document 15] in turn.

         MOTIONS TO DISMISS UNDER RULE 12(b)(6)

         I. Legal Standard

         In order to survive a motion to dismiss brought under Federal Rule of Civil Procedure 12(b)(6), a plaintiff must "state a claim to relief that is plausible on its face." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Id. at 678. "Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice." Id. The court must accept as true all of the factual allegations in the complaint in determining whether plaintiff has stated a plausible claim. See Bell Atlantic Corp. v. Twornbly, 550 U.S. 544, 555 (2007); In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007). However, a court is "not bound to accept as true a legal conclusion couched as a factual allegation." Papasan v. Allain, 478 U.S. 265, 286 (1986). If a complaint cannot meet this standard, it may be dismissed for failure to state a claim upon which relief can be granted. Iqbal, 556 U.S. at 678-79. A court does not evaluate a plaintiffs likelihood for success, but instead determines whether a plaintiff has pleaded a legally cognizable claim. United States ex rel. Riley v. St. Luke's Episcopal Hosp., 355 F.3d 370, 376 (5th Cir. 2004). A dismissal under 12(b)(6) ends the case "at the point of minimum expenditure of time and money by the parties and the court." Twombly, 550 U.S. at 558.

         II. Motion to Dismiss by Cox, Stewart and the Caddo Parish District Attorney's Office

         Plaintiff asserts claims against the Caddo Parish District Attorney's Office, Dale Cox in his individual capacity and in his official capacity as the former acting District Attorney of Caddo Parish, and against James Stewart[7] in his individual capacity and his official capacity as the current District Attorney of Caddo Parish. Record Document 1, ¶s 7, 8, & 12.

         In Count 1 of his complaint, Plaintiff claims that the District Attorney's Office and Cox violated his right to a fair trial. Id. at ¶s 81-87. According to Plaintiff, the District Attorney's Office failed to properly train and supervise Cox which allowed Cox to distort evidence, exhort Thoma and Traylor to testify falsely with "reckless disregard for the truth," improperly strike African-Americans from the jury, make "constitutionally improper" arguments at trial, and base Plaintiffs prosecution on religious and racial antipathy. Id.

         In Count 2, Plaintiff claims that the District Attorney's Office, Cox, and Stewart violated his right to liberty without due process of law. Id. at ¶s 88-91. Plaintiff makes the same allegations against the District Attorney's Office and Cox in Count 2 that he does in Count 1. Id. Plaintiff also claims that Stewart and the District Attorney's Office acted with deliberate indifference to his civil rights and pursuant to a policy of "deliberate inaction on admittedly innocent and wrongfully convicted inmates in their jurisdiction." Id.

         In Count 4, [8] Plaintiff asserts that Cox, Stewart, and the District Attorney's Office violated his right to equal treatment under the law because his investigation, detention, arrest, prosecution, and incarceration were based on intentionally unequal treatment and he is a member of a protected class. Id. at ¶s 92-94.

         In Count 5, Plaintiff claims that Cox and the District Attorney's Office used their peremptory challenges in a racially discriminatory manner during his criminal trial by using five of seven challenges to exclude African-Americans from the jury. Id. at ¶s 95-97. Plaintiff claims that this exclusion allowed Cox to freely use racial stereotypes at trial which led to a violation of Plaintiffs constitutional rights.

         In Count 6, Plaintiff alleges that the District Attorney's Office and Cox established policies, patterns, or practices that caused Plaintiff to be investigated, charged, detained, and prosecuted based on his race and that this led to his wrongful conviction. Id. at ¶s 98-102. Plaintiff claims that such policies were established with deliberate indifference and disregard for his constitutional and civil rights. Id. at ¶ 101.

         Finally, in Counts 7 and 8, Plaintiff claims that all Defendants are liable to him under state law for intentional infliction of emotional distress and tortious interference with a parent-child relationship. Id. at ¶s 103-106.

         In their motion to dismiss, Defendants first argue that Cox and Stewart are absolutely immune from Plaintiffs claims against them in their individual capacities under the doctrine of prosecutorial immunity. Record Document 16-1, p. 11. Defendants claim that they are not liable for any of Plaintiff s claims against the District Attorney's Office or against Cox and Stewart in their official capacities because Plaintiff has failed to sufficiently state a Monell claim for municipal liability under § 1983. Id. at 9 & 20. Defendants also allege that Plaintiff has no constitutional right to a fault-free investigation, fails to state a cause of action as to his claims regarding insufficient evidence, and fails to make allegations that Defendants fabricated evidence. Id. at 8, 16, & 22. Finally, Defendants argue that Plaintiff has not sufficiently stated a claim for relief on state law grounds and that the District Attorney's Office is not an entity that can be sued under Louisiana law. Id. at 23.

         A. Individual Capacity Claims

         To establish § 1983 claims against Cox and Stewart in their individual capacities, Plaintiff must demonstrate (1) a deprivation of a right secured by federal law, (2) that occurred under color of state law, and (3) was caused by a state actor. Victoria W. v. Larpenter, 369 F.3d 475, 482 (5th Cir. 2004). Section 1983 is violated only when a person deprives another of a constitutional or statutory right under color of state law. 42 U.S.C. § 1983 (2012); Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 49-50 (1999). Despite its broad reach, § 1983 was not intended to create a radical departure from ordinary common-law immunities that apply in tort suits. Rehberg v. Paulk, 566 U.S. 356, 361 (2012). The Supreme Court has recognized several categories of officials that are absolutely immune from lawsuits brought under § 1983 for actions taken within the legitimate scope of their duties, such as judges and legislators. Id. at 362. Inlmbler v. Patchman, the Supreme Court held that prosecutors were also absolutely immune from § 1983 suits because:

Such suits could be expected with some frequency, for a defendant often will transform his resentment at being prosecuted into the ascription of improper and malicious actions to the State's advocate. Further, if the prosecutor could be made to answer in court each time such a person charged him with wrongdoing, his energy and attention would be diverted from the pressing duty of enforcing the criminal law.

424 U.S. 409, 425 (1976) (internal citations omitted).

         Immunity from a § 1983 suit covers actions taken by a prosecutor in initiating prosecutions and presenting a criminal case on behalf of a state. Id. at 431. This immunity extends to actions taken by a prosecutor that are "intimately associated with the judicial phase of the criminal process" outside of a criminal trial. Loupe v. O 'Bannon, 824 F.3d 534, 538 (5th Cir. 2016) (quoting Imbler, 424 U.S. at 430). Such actions include pretrial court appearances by a prosecutor (Burns v. Reed, 500 U.S. 478, 492 (1991)); the decision to file charging documents and the preparation of those documents (Kalina v. Fletcher, 522 U.S. 118, 129 (1997)); and administrative obligations such as training, supervision, and information management that are directly connected with the conduct of trial (Van de Kamp v. Goldstein, 555 U.S. 335, 344 (2009)).

         Absolute immunity protects prosecutors regardless of their motives, even when they act maliciously, wantonly, or negligently. Brummett v. Cable, 946 F.2d 1178, 1181 (5th Cir. 1991); Loupe, 824 F.3d at 539 (quoting Rykers v. Alford, 832 F.2d 895, 897 (5th Cir. 1987)). This immunity prevents prosecutors from being held individually liable for constitutional violations resulting from actions taken within the legitimate scope of their prosecutorial duties, such as the suppression of exculpatory evidence (Cousin v. Small, 325 F.3d 627, 636 (5th Cir. 2003)) or state law claims such as malicious prosecution (Loupe, 824 F.3d at 539). Although prosecutorial immunity is broad, it is meant to protect the operations of the office itself rather than the interests of the occupant of that office. Id. at 538 (quoting Kalina, 522 U.S. at 125). When a court determines whether absolute immunity applies in a given case, it evaluates the nature of the function being performed rather than the identity of the person performing that function. Id. at 127.

         A prosecutor's actions are not covered by absolute immunity simply because a prosecutor performs them. Buckley v. Fitzsirnmons, 509 U.S. 259, 273 (1993). Prosecutors are not covered by absolute immunity when they perform investigative functions normally performed by a police officer or a detective. Id. A prosecutor's role in evaluating evidence and interviewing witnesses in preparation for trial is distinct from a detective's role in searching for clues and corroboration that might establish probable cause to arrest a suspect. Id. Investigative actions that would be covered only by qualified immunity if performed by a police officer or detective will not be covered by absolute immunity merely because they are performed by a prosecutor. Id. at 275.

         The Supreme Court established this distinction between advocacy and investigation in Buckley v. Fitzsimmons. In this case, the petitioner accused prosecutors of manufacturing false evidence that linked his boot to a boot print found at the scene of a murder and shopping for experts who would confirm their theories. Id. at 272. The prosecutors convened a special grand jury to investigate the murder before they had probable cause to arrest the petitioner or to initiate judicial proceedings against him. Id. at 274. The petitioner was not arrested until ten months after the grandy jury was convened. Id. at 275. The Supreme Court found that the prosecutors' mission when they convened the grand jury was entirely investigative in nature and that their conduct occurred well before they could claim to be acting as advocates for the state. Id. The Court concluded that absolute immunity did not apply to the prosecutors' actions because:

A prosecutor may not shield his investigative work with the aegis of absolute immunity merely because, after a suspect is eventually arrested, indicted, and tried, that work may be retrospectively described as "preparation" for a possible trial; every prosecutor might then shield himself from liability for any constitutional wrong against innocent citizens by ensuring that they go to trial.

Id. at 276. With these limits on the scope of absolute prosecutorial immunity in mind, the Court will now evaluate Plaintiffs claims against Cox and Stewart in their individual capacities. See id. at 273.

         1. Claims Against Cox Individually

         Most of Plaintiff s allegations against Cox in his individual capacity have to do with Cox's conduct during Plaintiffs criminal trial and are therefore barred by absolute prosecutorial immunity. Plaintiff first alleges that the prosecution at his trial, led by Cox, illegally excluded African-American jurors by using five of seven peremptory challenges to exclude African-Americans. Record Document 1, ¶s 86 & 96. While a good argument can be made that Cox did illegally exclude African-Americans from the jury, [9] this claim is directed towards actions Cox took while he was initiating and presenting a criminal case and is therefore barred by absolute immunity. Irnbler, 424 U.S. at 430-31. Furthermore, the Fifth Circuit has explicitly held that prosecutors are absolutely immune from personal liability for using peremptory strikes in a racially discriminatory manner. Esteves v. Brock, 106 F.3d 674, 677 (5th Cir. 1997) ("Because Brock's use of peremptory strikes in a racially discriminatory manner was part of her presentation of the state's case, she is entitled to absolute immunity from personal liability."). Thus, this claim by Plaintiff is barred by absolute immunity.

         Plaintiff further claims that Cox pursued a conviction and death sentence against him because of Cox's personal religious beliefs and mental instability even though there was insufficient evidence to support a prosecution [Record Document 1, ¶s 63-65], and that Cox made arguments based on racial stereotypes and animus [Id. at ¶s 66-67] and made "constitutionally improper" arguments at trial. Id. at ¶s 86 & 90. Again, these claims involve actions that Cox took when he was initiating a prosecution against Plaintiff and presenting the state's case against him. Absolute immunity applies to these actions regardless of motive, even if they were taken maliciously, wantonly or negligently. Loupe, 824 F.3d at 539 (quoting Rykers, 832 F.2d at 897). Plaintiffs claims regarding Cox's mental state and his alleged animus towards Plaintiff during his criminal prosecution are barred by absolute immunity.

         Plaintiff next claims that Cox, as the acting District Attorney of Caddo Parish during this prosecution and trial, adopted and implemented policies that led to unconstitutional actions, including the failure to supervise and train prosecutors to avoid wrongful convictions of African-American men. Id. at ¶ 12. But here again, Cox is protected by absolute prosecutorial immunity. In Van de Kamp v. Goldstein, the Supreme Court held that absolute immunity applied to a district attorney's alleged failure to properly train and supervise deputy district attorneys on their duty to provide impeachment-related information to a defendant because such activities required "legal knowledge and the exercise of related discretion." 555 U.S. at 344. Plaintiffs claims that Cox failed to properly train prosecutors in his office to avoid wrongful convictions of African-American men involve activities that similarly require legal knowledge and the exercise of discretion. These claims are thus barred by absolute immunity.

         Plaintiff claims that Cox distorted evidence against him and exhorted Defendants Traylor and Thoma to "testify falsely with reckless disregard for truth" at trial. Record Document 1, ¶s 85 & 90. Plaintiff does not specify what evidence against him was distorted by Cox, nor what Cox told Thoma and Traylor to say that was false, although this claim likely has to do with Thoma's and Traylor's testimony about the cause of Roderius's death.[10] The Supreme Court established absolute immunity for prosecutors in Imbler v. Patchman when it held that a prosecutor was immune from the plaintiffs claims under § 1983 that the prosecutor "with intent, and on other occasions with negligence," allowed a key witness to give false testimony at the plaintiffs criminal trial. 424 U.S. at 416. The Court acknowledged that absolute prosecutorial immunity leaves criminal defendants without civil redress when the malicious or dishonest actions of a prosecutor deprive them of liberty. Id. at 427. Furthermore, the Court opined that the alternative-qualified immunity for prosecutors-would endanger the functioning of the criminal justice system by preventing prosecutors from zealously performing their duties. Id. at 427-28. The Fifth Circuit adhered to this doctrine under similar facts in Cousin v. Small, where it found that a prosecutor was absolutely immune from the plaintiffs claims that he coerced and intimidated a witness into giving false testimony at the plaintiffs criminal trial. 325 F.3d at 632 & 635. Like the Supreme Court in Imbler, this Court acknowledges that the application of absolute prosecutorial immunity to Plaintiffs claims that Cox distorted evidence and encouraged witnesses to give false testimony against him may leave Plaintiff without civil redress for a genuine deprivation of liberty. However, the Supreme Court's holding in Imbler establishes that Cox is absolutely immune from these claims because they involve actions Cox took while he was initiating a prosecution and presenting the case for trial. See Imbler, 424 U.S. at 427-28.

         Finally, Plaintiff claims that Cox should be held individually responsible for actions that he took that were not connected to the initiation of prosecution or judicial proceedings. Record Document 1, ¶ 68. According to Plaintiff, Cox "participated in the investigation of the case including searching for the clues and corroboration that gave [him] putative probable cause to have [Plaintiff] arrested and then charged with capital murder." Id. This claim mirrors the language used by the Supreme Court in Buckley v. Fitzsimmons to distinguish between the role of an advocate and the role of a detective. 509 U.S. at 273. If Cox took on the role of a detective in his investigation of the state's case against Plaintiff, he could arguably be entitled to qualified immunity, but not absolute immunity, for such actions. Id. But the complaint contains no facts or further information as to the investigative actions Cox undertook. Thus, the Court does not decide the question of qualified immunity because Plaintiffs claim against Cox regarding the investigation is vague, conclusory, and does not provide enough facts to survive a motion to dismiss.

         Therefore, all of Plaintiff s claims against Cox in his individual capacity are DISMISSED WITH PREJUDICE.

         2. Claims Against Stewart Individually

         Stewart is the current District Attorney of Caddo Parish and had replaced Cox as the acting District Attorney at the time Plaintiffs conviction was overturned. Plaintiff alleges that Stewart required him to post a $50, 000 bond to secure his release from custody after the Louisiana Supreme Court reversed his conviction. Record Document 1, ¶ 74. This allegation appears to be the basis for Plaintiffs claim that Stewart acted with deliberate indifference to Plaintiffs civil rights and "pursuant to a policy of deliberate inaction on admittedly innocent and wrongfully convicted inmates." Id.

         To begin, this Court notes that the Louisiana Supreme Court did not declare Plaintiff "innocent." In fact, the Court found that there was enough evidence to support Plaintiffs conviction, but also found that his constitutional rights were violated when the district court improperly handled a Batson challenge. Crawford, 218 So.3d at 26 & 35. During trial, the district court found that the defense's Batson objection constituted a prima facie case of discrimination, but the district court did not require the prosecution to provide race-neutral justifications for peremptory strikes that the defense asserted were Batson violations. Id. at 35. Instead, the district court provided its own race-neutral justifications. Id. The Louisiana Supreme Court held that the error was sufficient to reverse Plaintiffs conviction and remanded the case for a new trial. Id. at 36. Plaintiff was required to post a $50, 000 bond while Stewart decided whether to refile the criminal charges, which he ultimately decided not to do. Record Document 1, ¶ 75. Plaintiff claims that Stewart was responsible for imposing this bond. Id.

         Plaintiffs allegation that Stewart required this bond stands in contrast to Louisiana Code of Criminal Procedure Article 314, which lists the different types of courts that have the authority to fix bail. District Attorneys do not have authority to fix bail in Louisiana. La. Code Crim. Proc. art. 314. Stewart might have requested that the state court set Plaintiffs bond at $50, 000, but he could not have imposed the bond himself. Furthermore, any request Stewart made regarding Plaintiffs bond is covered by absolute immunity because it is part of the initiation and presentation of a prosecution. Pinaud v. Cty. of Suffolk, 52 F.3d 1139, 1149 (2d Cir. 1995) ("[W]e cannot disagree with the holding of other circuits that actions in connection with a bail application are best understood as components of the initiation and presentation of a prosecution, and therefore are protected by absolute immunity.").

         Plaintiff also argues that Stewart failed to supervise and train prosecutors to determine whether a conviction is wrongful and exoneration appropriate. Record Document 1, ¶ 8. As stated above, district attorneys are absolutely immune from claims that they failed to train deputy district attorneys in areas that require legal knowledge and the exercise of related discretion. Van de Kamp, 555 U.S. at 344. Determining whether a conviction is wrongful and whether exoneration is appropriate clearly requires legal knowledge and Stewart is absolutely immune from these claims as well. Therefore, Plaintiffs claims against Stewart in his individual capacity are DISMISSED WITH PREJUDICE.

         B. Municipality/Official Capacity Claims

         Plaintiffs complaint contains allegations against Cox and Stewart in their official capacities as the former acting and current District Attorneys of Caddo Parish. Record Document 1, ¶s 8 & 12. It also names as a defendant the Caddo Parish District Attorney's Office. Id. at ¶ 7. However, Louisiana law does not allow a district attorney's office to be sued in its own name. Hudson v. City of New Orleans, 174 F.3d 677, 680 (5th Cir. 1999). Instead, claims against a district attorney's office must be brought against the current district attorney in his official capacity. Id. Furthermore, Cox's actions as the former District Attorney during Plaintiffs prosecution and conviction are imputed to the Caddo Parish District Attorney's Office via current District Attorney Stewart for the purposes of analyzing Plaintiffs municipal liability claims. Ford v. Caddo Parish, 15-0544, 2017 WL 6045465, at *2 (W.D. La. Dec. 6, 2017). Thus, procedurally, all claims against the Caddo Parish District Attorney's Office or against Cox in his official capacity as the former District Attorney of Caddo Parish must be DISMISSED WITH PREJUDICE. The Court will construe all such claims as claims against Stewart in his official capacity as the current District Attorney for Caddo Parish. The Court now turns to those claims. Plaintiffs municipal liability claims can be generally grouped into two categories: allegations of unconstitutional policies within the District Attorney's Office and allegations that the District Attorney's Office, Cox, and/or Stewart failed to adequately train and supervise their employees.

         1. Pol ...


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