Opinion

Charles v. LeBlanc

Court
District Court, W.D. Louisiana
Filed
Jun 6, 2025
Cited by
0 cases
Authority
More cited than 36.2%

“[I]t is always in the public interest to prevent the violation of a party’s constitutional rights.”

How later courts described this case

  • “[I]t is always in the public interest to prevent the violation of a party’s constitutional rights.”
  • “Public interest is near its zenith when ensuring that public organizations are being operated in accordance with the law. . . .”

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA

SHREVEPORT DIVISION

BRUCE CHARLES, ET AL. CIVIL ACTION NO. 18-0541

VERSUS JUDGE ELIZABETH E. FOOTE

JAMES M LEBLANC, ET AL. MAGISTRATE JUDGE HORNSBY

MEMORANDUM ORDER

Before the Court are three motions filed by Defendants. First, Defendants filed a

motion to stay pending appeal. Record Document 758. Plaintiffs opposed this motion,

and Defendants replied. Record Documents 761 & 798. Second, Defendants filed an

unopposed motion for clarification of this Court’s order denying Plaintiffs’ Federal Rules

of Civil Procedure 52(b) and 59(e) motion. Record Document 811 (seeking

clarification of Record Document 809). Defendants seek clarification as to whether the

Court intended to deny or otherwise comment on Defendants’ original motion to stay

through that order. at 3. Third, Defendants filed a renewed motion to stay pending

appeal. Record Document 827. Plaintiffs opposed this motion. Record Document

829.

For the following reasons, Defendants’ original motion to stay [Record Document

758] and Defendants’ renewed motion to stay [Record Document 827] are DENIED.

Defendants’ motion for clarification [Record Document 811] is DENIED AS MOOT in

light of the Court’s ruling on the motion to stay.

Background

Inmates at David Wade Correctional Center (“DWCC”) filed this class action suit

for injunctive and declaratory relief, challenging the conditions of confinement and

delivery of mental health services on extended lockdown. Plaintiffs alleged the policies

and practices in place at DWCC violated the Eighth Amendment of the United States

Constitution, Title II of the Americans with Disabilities Act (“ADA”), and Section 504 of

the Rehabilitation Act of 1973 (“RA”). The Court certified a class of all prisoners who are

or will be subject to extended lockdown at DWCC to pursue the Eighth Amendment claims

(the “Class”) and a subclass consisting of all individuals on extended lockdown at DWCC

who have or are perceived as having a qualifying disability related to mental health—as

defined by the ADA—to pursue the ADA and RA claims (the “Subclass”). Record

Document 462.

The Court bifurcated the trial in this matter into a liability phase and a remedy

phase. For the liability phase, the Court conducted a seventeen-day bench trial beginning

January 10, 2022. The Court considered evidence of prison conditions up to March 15,

2020. On November 1, 2022, the Court issued a 165-page opinion holding that (1)

Defendants violated the Eighth Amendment by housing inmates—including those with a

diagnosed mental illness—in inhumane conditions while on extended lockdown and by

failing to provide those inmates adequate mental health care; and (2) Defendants violated

the ADA and RA by failing to make reasonable accommodations for inmates with mental

disabilities and by employing unlawful methods of administration. Record Document

641.

Beginning on January 17, 2023, the Court conducted a fourteen-day bench trial

for the remedy phase. During this phase, the Court heard evidence of conditions of

confinement between March 15, 2020, and August 30, 2022.1 On July 18, 2024, the Court

issued an opinion [Record Document 754], Remedial Order [Record Document 755], and

Judgment [Record Document 756]. In its 172-page Opinion, the Court held that Plaintiffs

proved by a preponderance of the evidence that the Eighth Amendment, ADA, and RA

violations for which they sought protection had continued since the liability phase of trial

and would continue into the future. Record Document 754. The Court enjoined

Defendants from (1) continuing to violate the Eighth Amendment rights of the Class

through the unconstitutional conditions of confinement and provision of deficient mental

health services; and (2) continuing to violate the ADA and RA rights of the Subclass.

. Finally, the Court ordered Defendants to remedy the enumerated constitutional, ADA,

and RA violations. .

On August 2, 2024, Defendants appealed the July 18, 2024, rulings. That same

day, Defendants also sought a stay with this Court pending appeal and requested

expedited consideration. Record Document 758. On August 5, 2024, the Court denied

the request for expedited consideration. Record Document 762. On August 12, 2024,

1 Defendants repeatedly contend the cutoff date for discovery of prison conditions was in

error because they could not present evidence of current conditions. However, as this

Court has explained previously, “the Court has discretion to establish its own discovery

deadlines to promote the progression of trial.” Record Document 742 at 2. The Court

selected August 30, 2022, as the discovery cutoff date to end “the endless cycle of

discovery.” . Nevertheless, to ameliorate the effect of those rulings, the Court

incorporated a process into its Remedial Order to assess the current prison conditions.

before this Court ruled on the motion to stay, Defendants moved the United States Court

of Appeals for the Fifth Circuit to stay this Court’s orders pending appeal. Mot. Admin.

Stay & Stay District Ct.’s Order Pending Appeal, , No. 24-30484 (5th

Cir. Aug. 12, 2024), ECF. No. 16. On August 14, 2024, Plaintiffs filed their response to

the motion to stay filed in the Fifth Circuit. Opp’n to Mot. Admin. Stay & Stay District

Ct.’s Order Pending Appeal, , No. 24-30484 (5th Cir. Aug. 14, 2024), ECF. No. 28.

That same day, Plaintiffs also filed a motion in this Court urging it to enter additional

factual findings and/or amend the Court’s July 18, 2024, rulings in response to the

Defendants’ arguments in their Motion to Stay. Record Document 787 at 2.

Thereafter, the Fifth Circuit ordered Defendants’ appeal be held in abeyance until

this Court denied Plaintiffs’ cross-motion. , No. 24-30484, 2024 WL

3842581, at *2 (5th Cir. Aug. 16, 2024). On September 20, 2024, the Court denied

Plaintiffs’ cross-motion. Record Document 809. On September 27, 2024, Defendants

filed an unopposed motion for clarification of the Court’s denial of Plaintiffs’ cross-motion.

Record Document 811. Defendants seek clarification as to whether the Court

intended to deny the motion to stay, take no action on that motion, or rule on that motion

in a separate order.

On December 13, 2024, Defendants filed an opposed motion to stay further

proceedings in the Fifth Circuit pending the Fifth Circuit’s decision in ,

No. 23-30825 (5th Cir.). Mot. Stay Further Proceedings, , No. 24-30484 (5th

Cir. Dec. 13, 2024), ECF. No. 74. The Fifth Circuit granted that motion. Order,

, No. 24-30484 (5th Cir. Dec. 27, 2024), ECF No. 91. On February 12, 2025, the

Fifth Circuit panel dismissed the appeal for lack of jurisdiction and vacated the

stay of that district court’s remedial order. , 128 F.4th 691, 693 (5th

Cir. 2025). On April 22, 2025, the Fifth Circuit granted the Defendants’ petition for

rehearing en banc and vacated the previous February 12, 2025, panel decision.

, 134 F.4th 867, 868 (5th Cir. 2025).

On April 23, 2025, this Court convened a status conference to discuss the

procedural status of this case. Record Document 826. At the end of that status

conference, the Court ordered the parties to submit a proposed scheduling order by June

6, 2025, that addresses briefing deadlines for any pending motions (including the pending

motion to stay) and sets forth a plan for proceeding under the Court’s Remedial Order.

Following the submission of those scheduling orders, the Court intends to

“determine a realistic scheduling order for the parties moving forward.” at 2. On May

14, 2025, Defendants renewed their motion to stay and additionally moved to stay this

Court’s April 23, 2025, Order. Record Document 827.

Law & Analysis

In determining whether to grant a motion to stay pending appeal, courts consider

the following factors:

(1) whether the stay applicant has made a strong showing that he is likely

to succeed on the merits; (2) whether the applicant will be irreparably

injured absent a stay; (3) whether issuance of the stay will substantially

injure the other parties interested in the proceeding; and (4) where the

public interest lies.

, 769 F.3d 890, 892 (5th Cir. 2014) (quoting , 556 U.S.

418, 426 (2009)). A balancing of these factors clearly indicates that the motion to stay

must be denied.

First, Defendants are not likely to succeed on the merits. Defendants point to four

alleged errors that they argue make them likely to succeed on the merits on appeal: “(1)

the Remedial Order violates principles of federalism; (2) the Remedial Order is

impermissibly vague and overbroad . . . ; (3) the Remedial Order violates the

requirements of the PLRA . . . ; and (4) the Remedy Opinion and Remedial Order are not

based upon current conditions . . . .” Record Document 759 at 12. Defendants additionally

argue that the Fifth Circuit’s decision to rehear en banc supports staying this

matter pending appeal. Record Document 827.

Having reviewed Defendants’ arguments, the Court does not find Defendants are

likely to succeed on appeal. The Court conducted two trials in this matter, for a combined

total of days. During those trials, the Court heard extensive evidence of the

conditions at DWCC. The Court subsequently issued detailed findings of law and fact in

two opinions and related orders, totaling over 300 pages. Defendants’ purported errors

do not affect the validity and propriety of the Court’s rulings. Thus, Defendants are not

likely to succeed on the merits.

Nor does the third factor support a stay. Defendants argue Plaintiffs will not be

substantially harmed because current prison conditions are “more than constitutional.”

Record Document 759 at 26. In so arguing, Defendants seek to ignore both the

evidence of constitutional violations the Court considered during the trial and this Court’s

attempt to survey current conditions through the process set out in its Remedial Order.

Defendants additionally point to the procedural history of this case, arguing that the

length of time this case was under advisement indicates the Court does not believe

Plaintiffs are being substantially injured. . This argument is wholly without merit.

The time the Court spent considering this case evidences the seriousness with which the

Court undertook its analysis of the conditions at DWCC. Thirty-one days of trial and over

300 pages of opinions considering the conditions and potential remedies do, of course,

take time. Having found Defendants violated the constitutional and statutory rights of

Plaintiffs, any further delay would be a disservice to both Plaintiffs and the public and

would result in substantial, irreparable harm to Plaintiffs.

For this reason, too, the fourth factor weighs in favor of Plaintiffs because a stay

does not lie in the public interest. As Defendants note, “[t]he public has a vested interest

in the operation and security of prisons within the State of Louisiana.” Record Document

759 at 26. Thus, the public has a vested interest in ensuring that the operation of prisons

is constitutional and does not violate the law. , 465 F.3d 174, 180-

81 (5th Cir. 2006) (“Public interest is near its zenith when ensuring that public

organizations are being operated in accordance with the law. . . .”) (quoting

, 800 F.2d 613, 616 (6th Cir.1986)); , 760

F.3d 448, 458 n. 9 (5th Cir. 2014) (“[I]t is always in the public interest to prevent the

violation of a party’s constitutional rights.”); , No. 23-CV-

272, 2025 WL 863640, at *4 (S.D. Miss. Mar. 19, 2025) (“The public has a strong interest

in protecting constitutional rights.”). In this Court’s purview, that interest certainly

outweighs the Defendants’ proffered interest of the “substantial costs to be borne by the

taxpayers of the State of Louisiana.” Record Document 759 at 26. Therefore, the public

interest lies with Plaintiffs.

Finally, even if Defendants have shown they may be irreparably harmed by

compliance costs, that factor is heavily outweighed by the remaining factors. Defendants’

argument as to irreparable harm contradicts their argument that current prison conditions

are “more than constitutional.” . Defendants argue they will be burdened with

“astronomical costs” and will be “forced to operate [this] correctional system under the

purview of the federal government.” . at 24, 26. But if Defendants are indeed

correct that they have remedied the constitutional and statutory violations at DWCC, their

costs and obligations under the Remedial Order will be relatively minimal. And the minimal

cost of that compliance is, of course, justified by this Court’s extensive findings of

constitutional and statutory violations affecting Plaintiffs. Therefore, even to the extent

that Defendants will be “irreparably harmed” by compliance costs, that factor is heavily

outweighed by the remaining three factors.2

After extensive consideration of the merits, the Court found that the conditions at

DWCC violated Plaintiffs’ constitutional and statutory rights and that these violations were

likely to continue. To further delay remediation of these violations, Defendants filed the

instant motions. The harms and costs Defendants allege they will suffer if this Court

proceeds are negligible in light of the severe harms being sustained by Plaintiffs. This is

2 Notably, at present, Defendants’ only obligation is to submit a proposed scheduling

order to this Court for consideration.

especially so considering that the Remedial Order is not the final iteration of this Court’s

injunctive relief. Instead, the Remedial Order simply sets out a process for determining if

Defendants continue to engage in the identified violations. If—as Defendants allege—

they have remediated the identified violations, the cost and burden of complying with

this process should be minimal. Because the stay factors weigh heavily in favor of

Plaintiffs, the non-movant, Defendants’ motion to stay must be denied.

Conclusion

For the reasons assigned herein, IT IS ORDERED that Defendants’ original

motion to stay [Record Document 758] and Defendants’ renewed motion to stay [Record

Document 827] are DENIED. The Court’s order for the parties to submit a proposed

scheduling order by June 6, 2025 [Record Document 826] is still in effect.

IT IS FURTHER ORDERED that Defendants’ motion for clarification [Record

Document 811] is DENIED AS MOOT in light of the Court’s ruling on the motion to stay.

6th

THUS DONE AND SIGNED this/ 5th day of June, 2025.

ELIZABETH ERNY FOOTE

UNITED STATES DISTRICT JUDGE

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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