Reel v. Louisiana State Penitentiary

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
RONALD REEL (#356002) CIVIL ACTION NO.
VERSUS 26-149-SDD-EWD
LOUISIANA STATE PENITENTIARY
RULING AND ORDER
This matter comes before the Court on the Complaint of Plaintiff Ronald Reel
("Reel"), who is representing himself and who is confined at the Louisiana State
Penitentiary ("LSP").1 The Court construes the Complaint as a Motion for Preliminary
Injunction and Temporary Restraining Order.2
Reel asserts that video footage from the main prison, cell block-B, lower-left tier
from January 9, 2026 at 7:15 A.M. to 7:45 A.M. and January 16, 2026 at 10:00 A.M. to
11:00 A.M. in the same location will be used in future litigation, but states that any such
video footage will be recorded over within approximately 40 days from the date recorded.
He cannot, prior to the expiration of this period, exhaust his administrative remedies and
file suit. However, the plaintiff does anticipate filing suit after exhausting his administrative
remedies and asserts that the video footage he seeks to have preserved would be used
as evidence in his future litigation.
1R. Doc. 1.
2R. Doc.1.
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"A preliminary injunction is an extraordinary and drastic remedy; it is never
awarded as of right."3 The decision whether to grant or deny a request for a preliminary
injunction is within the sound discretion of the Court.4
At all times, the burden of persuasion remains with the plaintiff as to each of the
four elements. Specifically, a plaintiff must establish: (1) a substantial likelihood of
prevailing on the merits; (2) a substantial threat of irreparable injury if the injunction is not
granted; (3) the threatened injury outweighs any harm that will result to the non-movant if
the injunction is granted; and (4) the injunction will not disserve the public interest.5 If a
plaintiff fails to meet his burden regarding any of the necessary elements, the Court need
not address the other elements necessary for granting a preliminary injunction.6
While the Court: understands the procedural quandary in which the plaintiff finds
himself, the Court cannot determine that the plaintiff has a substantial likelihood of
prevailing on the merits. The entire record consists only of the plaintiff's instant motion
which does not provide the details of his future claims. Additionally, the Court cannot find
that there is a substantial threat of irreparable injury if an injunction is not granted. The
Fifth Circuit permits an adverse inference against the destroyer of evidence upon a
3 Munafv. Geren, 553 U.S. 674, 689-90 (2008) (internal citations and quotations omitted). See also Allied
Marketing Group., Inc. v. CDL Marketing, Inc., 878 F.2d 806, 809 (5th Cir. 1989) (preliminary injunctive
relief "is an extraordinary remedy and should be granted only if the movant has clearly carried the burden
of persuasion with respect to all four factors"); Mississippi Power & Light Co. v. United Gas Pipe Line Co.,
760 F,2d 618, 621 (5th Cir. 1985) ("[t]he decision to grant a request for preliminary injunction is to be treated
as the exception rather than the rule").
4 See Allied Mlttg. Grp., Inc., 878 F.2d at 809.
5 See Ridgely v. Fed. Emergency Mgmt. Agency, 512 F.3d 727, 734 (5th dr. 2008).
6 See Roho, Inc. v. Marquis, 902 F.2d 356, 261 (5th Cir. 1990) (declining to address the remaining elements
necessary to obtain a preliminary injunction after finding that the plaintiff failed to show a substantial
likelihood of success on the merits).
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showing of bad faith or bad conduct.7 Where the facts and circumstances may not
demonstrate bad faith justifying an adverse inference, district courts can "admit the fact
of the destruction of [evidence] for the jury to weigh with the other evidence in the case.8
It is unclear whether Warden Darrel Vannoy is aware yet of Reel's complaints, but to the
extent the video footage has not yet been overwritten,9 this Ruling provides notice that
future litigation is expected and evidence to that litigation exists in the video footage noted
above. Accordingly,
IT IS ORDERED that the plaintiff's Motion (R. Doc. 1) be and is hereby DENIED.
IT IS FURTHER ORDERED that Warden Darrel Vannoy and Louisiana Attorney
General Elizabeth Murrill shall be served, via CM/ECF and by certified mail, with a copy
of this Order which provides each with notice of the plaintiff's request that the noted video
footage not be overwritten or destroyed.
IT IS FURTHER ORDERED, with no case or controversy remaining before the
Court, that this action be DISMISSED without prejudice, and that this matter be closed.
Judgment shall be entered accordingly.
Signed in Baton Rouge, Louisiana, on February 12, 2026.
cXlA/^^/fu^/-
CHIEF JUDG^/SHELLY D. DICK
UNITED STXTES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
7 Condreyv. SunTrust Bank of Georgia, 431 F.3d 191, 203 (5th Cir. 2005).
8 Caparotta v. Entergy Corp., 168 F.3d 754, 756 (5th Cir. 1999).
9 The footage from January 16, 2026 should be available.
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