Brown v. St. Tammany Parish Detention Center/Jail et al

ERIN WILDER-DOOMES
UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
RASHAD LAMAR BROWN (#219041) 	CIVIL ACTION NO.
VERSUS 	24-913-SDD-EWD
ST. TAMMANY PARISH DETENTION
CENTER/JAIL, ET AL.
NOTICE
Please take notice that the attached Magistrate Judge’s Report has been filed with the Clerk
of the U. S. District Court.
In accordance with 28 U.S.C. § 636(b)(1), you have 14 days after being served with the
attached report to file written objections to the proposed findings of fact, conclusions of law, and
recommendations set forth therein. 	Failure to file written objections to the proposed findings,
conclusions and recommendations within 14 days after being served will bar you, except upon
grounds of plain error, from attacking on appeal the unobjected-to proposed factual findings and
legal conclusions accepted by the District Court.
ABSOLUTELY 	NO 	EXTENSION 	OF 	TIME 	SHALL 	BE 	GRANTED 	TO 	FILE
WRITTEN OBJECTIONS TO THE MAGISTRATE JUDGE’S REPORT.
Signed in Baton Rouge, Louisiana, on December 8, 2025.
S
Case 3:24-cv-00913-SDD-EWD Document 15 12/08/25 Page 1 of 6

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
RASHAD LAMAR BROWN (#219041) 	CIVIL ACTION NO.
VERSUS 	24-913-SDD-EWD
ST. TAMMANY PARISH DETENTION
CENTER/JAIL, ET AL.
MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION
Before the Court is the Complaint of Rashad Lamar Brown (“Brown”), who is representing
himself and who is confined at the Eastern Louisiana Mental Health System in Jackson,
Louisiana.1 Based on the screening required by 28 U.S.C. § 1915A and permitted by 28 U.S.C. §
1915(e), it is recommended that Brown’s federal claims be dismissed with prejudice for failure to
state a claim, that the Court decline to exercise supplemental jurisdiction over Brown’s potential
state law claims, and that this case be closed.
I. 	BACKGROUND
Brown filed this lawsuit against multiple Defendants under 42 U.S.C. § 1983, alleging
various violations of his constitutional rights, which appear to arise from alleged “false arrest” and
“illegal holding.”2 He requests money damages and injunctive relief.3
II. 	LAW & ANALYSIS
A. Standard of Review
This Court may dismiss a claim by a prisoner against a governmental entity or an officer
or employee of a governmental entity, or by any other plaintiff who has been given permission to
1 R. Doc. 1. Documents filed into the record are referred to as “R. Doc. __.” Brown also filed several other “NOTICES”
into the record. See R. Docs. 3, 4, 7, 8, 9, 10, 11, 12, 13. These documents are not properly before the Court; to the
extent the “NOTICES” raise new claims, those claims have not been considered as they would not be properly joined
with the claims in this case under Federal Rules of Civil Procedure 18 and 20. To the extent the “NOTICES” contain
additional facts to support claims contained in the originally filed Complaint, the facts have been considered, and the
claims still fail.
2 See R. Doc. 1.
3 R. Doc. 1, p. 5.
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file suit without prepaying the filing fee (“IFP status”), if the claim is frivolous, malicious, or fails
to state a claim upon which relief may be granted.4 Because Brown has sued government officials
and has been given IFP status, his case is subject to screening. The screening process gives the
court the ability early in the case to separate those claims that may have merit from those that lack
a basis in fact or in law. Dismissal of any claim that does not pass screening may be made before
service of process or before any defendant has answered the suit.
To determine whether a complaint fails to state a claim for purposes of screening under §§
1915(e) and/or 1915A, courts apply the same standard used for dismissal under Federal Rule of
Civil Procedure 12(b)(6).5 	This means the court must accept all well-pleaded facts as true and
view them in the light most favorable to the plaintiff.6 To survive screening, “a complaint must
contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its
face.’”7 “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.”8
To avoid dismissal, a complaint must contain enough factual information to raise a reasonable
expectation that discovery will provide evidence of each element of the plaintiff’s claim.9
4 28 U.S.C. §1915(e) provides for dismissal of claims that are frivolous, malicious, or fail to state a claim where the
plaintiff was granted IFP status. 	28 U.S.C. §1915A provides for dismissal of claims by prisoners against a
governmental entity or employee of a governmental entity for the same reasons regardless of the pauper status of the
plaintiff. Brown was granted IFP status on January 3, 2025. R. Doc. 5.
5 Bazrowx v. Scott, 136 F.3d 1053, 1054 (5th Cir. 1998) (recognizing that the standards for determining whether a
complaint fails to state a claim for relief are the same under 28 U.S.C. §§ 1915(e)(2)(B)(ii) and 1915A and Fed. R.
Civ. P. 12(b)(6)).
6 Baker v. Putnal, 75 F.3d 190, 196 (5th Cir. 1996).
7 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).
8 Id.
9 AGEM Management Services, LLC v. First Tennessee Bank Nat. Ass’n, 942 F.Supp.2d 611, 617 (E.D. La. April 25,
2013), citing Lormand v. U.S. Unwired, Inc., 565 F.3d 228, 255-57 (5th Cir. 2009).
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B. Brown Does not State a Cognizable Claim
Brown’s claims are jumbled and difficult to decipher, but he states in a conclusory fashion
that “officers, officials, along with everyone else” are violating Brown’s First, Eighth, and
Fourteenth Amendment rights.10 The remainder of the original Complaint and the notices are
mostly gibberish with little to no complete sentences and instead include random words, phrases,
and dates that this Court cannot make sense of. “[W]holly conclusory” and “fatally vague” claims
are properly dismissed as frivolous pursuant to 28 U.S.C. § 1915(e) and 1915A. 11
Deciphering the ramblings to the best of the Court’s ability, it appears that at least one of
Brown’s claims is that he was falsely arrested and is being illegally detained, so he seeks
immediate release.12 To the extent Brown challenges his conviction,13 the proper way to challenge
a state criminal conviction and seek release is through an application for a writ of habeas corpus
brought under 28 U.S.C. § 2254. 14 Although a § 1983 suit may be considered a habeas application
in some situations, the Court should not do so in this case considering the conclusory nature of the
10 R. Doc. 1, p. 4.
11 Bilbrew v. Johnson, 239 Fed.Appx. 49, 51 (5th Cir. 2007).
12 R. Doc. 1, p. 4. See also R. Doc. 10-1, p. 3 (Brown alleges in a conclusory fashion that he is being illegally held at
the St. Tammany Parish Detention Center). To the extent Brown is attempting to make other claims, it does not appear
those claims would be properly joined under Federal Rules of Civil Procedure 18 and 20, so even if the Court could
decipher what those claims might be, they would be severed from this action as improperly joined. If Brown would
like to bring any other claims, he should do so by filing a new suit.
13 It is unclear whether Brown is challenging a conviction or if he is awaiting trial. If Brown has not been convicted,
this Court should abstain from interfering with state court proceedings, even if Brown had stated any cognizable
claims. Younger v. Harris, 401 U.S. 37 (1971). In this case, the Court should still dismiss the claims as vague,
conclusory. Bilbrew, 239 Fed.Appx. at 51. The claims for money damages are also Heck barred.
14 See Preiser v. Rodriguez, 411 U.S. 475, 500 (1973) (a challenge by a prisoner to the fact or duration of his
confinement and seeking immediate or earlier release from that confinement must be pursued through a habeas corpus
proceeding rather than through an ordinary civil rights action); see also, Wilkinson v. Dotson, 544 U.S. 74, 78 (2005),
quoting Preiser, 411 U.S. at 498 (“prisoner in state custody cannot use a § 1983 action to challenge ‘the fact or duration
of his confinement.’”).
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claims and the bare allegations before it, as well as the fact that there are no allegations that indicate
Brown exhausted his state court remedies.15
To the extent Brown seeks monetary damages, in Heck v. Humphrey, 16 the Supreme Court
held that a claim that effectively attacks the constitutionality of conviction or imprisonment cannot
be brought under § 1983 unless and until that conviction or sentence has been “reversed on direct
appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such
determination, or called into question by a federal court’s issuance of a writ of habeas corpus.” 17
Since his conviction or sentence have not been reversed, expunged, declared invalid, or called into
question in any way, any request for monetary damages under 42 U.S.C. § 1983 because Brown
believes he was unconstitutionally imprisoned is barred by Heck v. Humphrey. Therefore, Brown
fails to state a claim upon which relief may be granted for alleged “illegal holding”18 and those
claims should be dismissed under 28 U.S.C. §§ 1915(e) and 1915A.19
C. Further Leave to Amend is Not Warranted
Though “[o]rdinarily, a pro se litigant should be offered an opportunity to amend his
complaint before it is dismissed…[g]ranting leave to amend…is not required if the plaintiff has
already pleaded her best case.”20 	As noted above, Brown has filed numerous “NOTICES”
attempting to explain his claims, so it is unnecessary for the Court to continue entertaining
15 Walker v. Miss. Parole Bd., 333 Fed.Appx. 843, 844 (5th Cir. 2009) (“The district court properly declined to construe
Walker's complaint as a habeas petition because Walker failed to exhaust his state remedies.”). Research also did not
reveal any state court decisions involving Brown, further supporting the conclusion that Brown never exhausted his
habeas claims through the state’s highest court, as would be required to exhaust remedies.
16 512 U.S. 477 (1994).
17 Id. at 486-87. See also Wells v. Bonner, 45 F.3d 90, 94 (5th Cir. 1995).
18 R. Doc. 1, p. 4.
19 To the extent Brown has not yet been convicted, the Heck bar still applies. See Galloway v. Garber, No. 24-1629,
2025 WL 957224, at *4 (W.D. La. March 13, 2025).
20 Wiggins v. Louisiana State University—Health Care Services Division, 710 Fed. Appx. 625, 627 (5th Cir. 2017)
(internal quotation marks omitted).
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ERIN WILDER-DOOMES
UNITED STATES MAGISTRATE JUDGE
unlimited pleadings from Brown. Further, Brown’s claim for false arrest and illegal imprisonment
are incurable, so amendment would be futile.21
D. Exercise of Supplemental Jurisdiction Should be Declined
To the extent that Brown may be asking the Court to exercise supplemental jurisdiction
over potential state law claims, a district court may decline the exercise of supplemental
jurisdiction if a plaintiff’s state law claims raise novel or complex issues of state law, if the claims
substantially predominate over the claims over which the district court has original jurisdiction, if
the district court has dismissed all claims over which it had original jurisdiction, or for other
compelling reasons.22 	In this case, because it is recommended that Brown’s federal claims be
dismissed, it is further recommended that the Court decline to exercise supplemental jurisdiction
over any possible state law claims.
III. 	RECOMMENDATION
IT IS RECOMMENDED that the Court decline to exercise of supplemental jurisdiction
over potential state law claims, that all federal claims brought by Plaintiff Rashad Lamar Brown
in this case be DISMISSED WITH PREJUDICE under 28 U.S.C. §§ 1915(e) and 1915A for
failure to state a claim upon which relief may be granted, and that this case be CLOSED. 23
Signed in Baton Rouge, Louisiana, on December 8, 2025.
S
21 As noted above, to the extent Brown attempts to bring claims unrelated to the alleged false arrest and illegal
imprisonment, those claims would not be properly joined in this action, so allowing amendment in this case with
respect to those claims would also be improper.
22 28 U.S.C. § 1367.
23 Plaintiff, Rashad Lamar Brown, is advised that 28 U.S.C. § 1915(g) provides that, “In no event shall a prisoner
bring a civil action or appeal a judgment in a civil action or proceeding under this section [Proceedings in forma
pauperis] if the prisoner has, on 3 or more prior occasions, while incarcerated or detained in any facility, brought an
action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or
fails to state a claim upon which relief may be granted, unless the prisoner is under imminent danger of serious physical
injury.” Should this Report and Recommendation be adopted, the Ruling in this matter will count as a strike.
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