Eusea v. St. Charles Parish Sheriff's Office

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA ERNEST EUSEA * CIVIL ACTION NO. 23-6643 * VERSUS * SECTION: “A”(4) * ST. CHARLES PARISH SHERIFF’S * JUDGE JAY C. ZAINEY OFFICE ET AL. * * MAGISTRATE JUDGE KAREN WELLS * ROBY * ORDER AND REASONS Ernest Eusea brought this suit pro se against the Sheriff’s Office and the 29th Judicial District Court for the Parish of St. Charles. He alleges that the Sheriff’s Office pulled him over for speeding and arrested and cited him for operating a motor vehicle without a driver’s license. This citation was ultimately adjudicated in the 29th Judicial District Court. Eusea asserts that the Sheriff’s Office and the 29th Judicial District Court each violated his rights and were unauthorized to exercise jurisdiction over him. Louisiana does not recognize Sheriff’s Offices or Judicial District Courts as entities capable of being sued. The Louisiana Supreme Court has made it clear that “[i]t is well settled ... that a Sheriff’s Department is not a legal entity capable of being sued.” Valentine v. Bonneville Ins. Co., 691 So. 2d 665 , 668 (La. 3/17/97). Under Louisiana law, an entity must qualify as a “juridical person” to possess the capacity to be sued. Griffith v. Louisiana, 808 F.Supp.2d 926, 933 (E.D. La. 2011) (Berrigan, J.) (noting Dugas v. City of Breaux Bridge Police Dep't, 757 So. 2d 741, 743 (La. App. 3 Cir. 2000)). A juridical person is “an entity to which the law attributes personality.” LA. CIV. CODE. ANN. art. 24. Louisiana's state courts are created by the Louisiana Constitution as component parts of a unified state system for the exercise of the state's judicial power. Id. at *5 (citing LA. CONST., art. 5 $§ 1, 16). Thus, the 29th Judicial District Court is not a separate entity, but rather a part of the state government’s judicial branch. /d. Further, no law, constitutional, statutory, or otherwise, confers upon the 29th Judicial District Court the authority to sue or be sued. See Griffith, 808 F.Supp.2d at 934 (citations omitted). Accordingly; IT IS ORDERED that Plaintiff’s claims against the St. Charles Parish Sheriff's Office and the 29th Judicial District Court for the Parish of St. Charles are DISMISSED WITH PREJUDICE. September 15, 2025 Cc ( de C. A UNITED STATES DISTRICT JUDGE