Payton v. Town of Maringouin et al
RULING AND ORDER denying 123 124 Motions for Reconsideration. Signed by Judge John W. deGravelles on 10/5/2021. (EDC)
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
TOWN OF MARINGOUIN
RULING AND ORDER
This matter comes before the Court on two motions. The first is Hosea Anderson, Terrance
Davis and the Town of Maringouin’s Motion for Reconsideration under Federal Rule of Civil
Procedure 59(e) (Doc. 123). The second is the Motion for Reconsideration of Supplemental
Jurisdiction (R. Docs. 119 and 120) (Doc. 124) filed by Defendants, RJ’s Transportation, LLC and
Patrick Ventress (Anderson, Davis, the Town of Maringouin, RJ’s Transportation, LLC and
Ventress are, collectively, “Moving Defendants”). Plaintiff Cynthia Payton opposes the motions,
(Doc. 129), and Moving Defendants have filed separate reply briefs, (Docs. 131, 132). Oral
argument is not necessary. The Court has carefully considered the law, the facts in the record, and
the arguments and submissions of the parties and is prepared to rule. For the following reasons,
Moving Defendants’ motion is denied.
Relevant Background and Parties’ Arguments
On June 21, 2021, this Court issued a ruling on four pending motions for summary
judgment. (Doc. 118.) In short, the Court dismissed all pending federal claims against Moving
Defendants and denied without prejudice the motions with respect to the state law claims. (Id. at
79–80.) The Court gave Plaintiff an opportunity to brief why the federal claims against two nonmoving defendants, Edward James and Dwayne Bourgeois, should not be dismissed for the same
reasons given in the Court’s Ruling and Order. (Id. at 80). Plaintiff did not brief the issue, and the
Court entered a sua sponte order dismissing the non-moving defendants and declining to exercise
supplemental jurisdiction over all state law claims. (Doc. 119.) Judgment was then entered. (Doc.
Moving Defendants now file the above motions for reconsideration. (Docs. 123, 124.) In
sum, they argue that, because the Court already ruled that there was probable cause for Plaintiff’s
arrest, all state law claims necessarily fall. Moving Defendants further contend that the statutory
and common law factors identified in the Court’s sua sponte order (Doc. 119) all weigh in favor
of retaining jurisdiction over the state law claims.
Plaintiff opposes the motion. She maintains, inter alia, that Moving Defendants will suffer
no real prejudice (or at least, no more prejudice than any other case where the Court declines to
exercise supplemental jurisdiction), that Defendants will not need to duplicate resources, that
Plaintiff herself is prejudiced, that the analysis of the state law claims differs from that of the
federal claims, and that Moving Defendants have not shown that the Court abused its discretion.
Moving Defendants reply by reiterating that Plaintiff’s state law claims fall on probable
cause. Further, they assert, among other arguments, that Plaintiff’s position is inconsistent;
Plaintiff’s state law claims cannot simultaneously be so unique as to warrant separate consideration
by the state court but so similar as to avoid duplication of resources.
Law and Analysis
“Because [Moving Defendants’] motion ‘calls into question the correctness’ of the
judgment, [the Court] consider[s] it under Rule 59(e).” Allen v. Envirogreen Landscape Pros.,
Inc., 721 F. App'x 322, 328 (5th Cir. 2017) (quoting Templet v. HydroChem Inc., 367 F.3d 473,
478 (5th Cir. 2004) (quoting In re Transtexas Gas Corp., 303 F.3d 571, 581 (5th Cir. 2002))).
“Rule 59(e) motions serve ‘the narrow purpose of allowing a party to correct manifest errors of
law or fact or to present newly discovered evidence.’ ” Id. (quoting Templet, 367 F.3d at 478
(quoting Waltman v. Int'l Paper Co., 875 F.2d 468, 473 (5th Cir. 1989))). “Reconsideration of a
judgment after its entry is an extraordinary remedy that should be used sparingly.” Id. (quoting
Templet, 367 F.3d at 479 (citation omitted)).
Having carefully considered the matter, the Court will deny Moving Defendants’ motion
The Court agrees with Plaintiff that the framework for analyzing the state law claims is sufficiently
different to warrant remanding this case to state court for separate consideration. For example, the
Court dismissed Plaintiff’s federal malicious prosecution claim because “[t]here is no freestanding
right under the Constitution to be free from malicious prosecution.” (Doc. 118 at 32 (quoting
Anokwuru v. City of Hous., 990 F.3d 956, 964 (5th Cir. 2021)).) A state court malicious
prosecution claim will certainly not fall on that ground.
The Court also concurs with Plaintiff that Moving Defendants largely focus on prejudice
to themselves without looking at the factors analyzed by the Court as a whole. Moving Defendants
concede that two of four statutory factors weigh in favor of remand, (Doc.123-1 at 9), and the
Court finds that it properly weighed the common law factors, as quoted by Plaintiff in her
opposition memorandum, (Doc. 129 at 6–7 (quoting Doc. 119 at 4).)
Lastly, the Court disagrees with Defendants that Plaintiff’s position is inconsistent; the fact
that there is some overlap in discovery does not preclude the possibility that Plaintiff’s state law
theories differ from her federal theories, or that Moving Defendants will have already engaged in
such discovery in preparation for the summary judgment motions.
Ultimately, Moving Defendants may disagree with the Court’s result, but they have not
shown that the Court abused its discretion in weighing the statutory and common law factors. (See
Doc. 119 at 2–6.) Nor have they demonstrated that the Court erred to such a degree as to commit
a “manifest error of law or fact.” Allen, 721 F. App’x at 328.
IT IS ORDERED that Hosea Anderson, Terrance Davis and the Town of Maringouin’s
Motion for Reconsideration under Federal Rule of Civil Procedure 59(e) (Doc. 123) and the
Motion for Reconsideration of Supplemental Jurisdiction (R. Docs. 119 and 120) (Doc. 124) filed
by Defendants, RJ’s Transportation, LLC and Patrick Ventress are DENIED.
Signed in Baton Rouge, Louisiana, on October 5, 2021.
JUDGE JOHN W. deGRAVELLES
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
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