GYDEN
v.
DIXSON
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A Florida prisoner filed a civil rights complaint under 28 U.S.C. § 2254 alleging that Florida Department of Corrections officials violated his First Amendment right to free exercise of religion by denying him and other Hebrew-Israelites the right to wear diadems during religious activities. The district court dismissed claims against two individual defendants as duplicative of the official-capacity claim against the Secretary of the Florida Department of Corrections.
The court held that official-capacity claims against Sabatier-Smith and Bowden are duplicative of the official-capacity claim against Secretary Dixon and must be dismissed, because claims against defendants in their official capacities are suits against the entity itself rather than the individuals. The action will proceed solely against Secretary Dixon in his official capacity regarding the First Amendment free exercise claim.
[1] Official-capacity claims against multiple defendants who are agents of the same government entity are duplicative and must be dismissed.
[2] A suit against a government official in their official capacity is a suit against the government entity they represent.
Previewing 2 of 2 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“A claim against a defendant in his official capacity is a suit against the entity of which the named defendant is an agent— here, the Florida Department of Corrections.”
Establishes the fundamental principle that official-capacity suits target the governmental entity, not the individual defendant
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Join FLexlaw to unlock all legal intelligencePlaintiff, an incarcerated person in Florida, alleged that in August 2022, chaplain Paul Sabatier-Smith denied him and other Hebrew-Israelites the rig…
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Before the Court is Plaintiff's second amended civil rights complaint filed under 28 U.S.C. § 2254 (Doc. 21). Plaintiff, a Florida prisoner, alleges that Defendants (Rickey Dixon, Secretary of the Florida Department of Corrections; T. Bowden, Dixon's representative; and Paul Sabatier-Smith, the chaplain at Hardee Correctional Institution) violated his First Amendment right to free exercise of religion. Specifically, he alleges that in August 2022, Sabatier-Smith denied him and other Hebrew-Israelites their right to wear diadems during a prayer meeting and study class. Plaintiff also alleges that in denying him his right to wear a diadem, Sabatier-Smith was enforcing an official policy or rule of the Florida Department of Corrections. Dixon and Bowden denied Plaintiff's grievance about the matter. Plaintiff sues Defendants solely in their official capacities. As relief, Plaintiff seeks a declaration that Defendants violated his rights under the First Amendment, and an injunction providing him and other Hebrew-Israelites the same right to wear head coverings as Jewish, Muslim, and 1
Catholic prisoners have in the Florida Department of Corrections.
A claim against a defendant in his official capacity is a suit against the entity of which the named defendant is an agent— here, the Florida Department of Corrections. Owens v. Fulton Cnty., 877 F. 2d 947, 951 n.5 (11th Cir. 1989) (citing Kentucky v. Graham, 473 U.S. 159, 165–66 (1985)). Thus, the official-capacity claims against Sabatier-Smith and T. Bowden are duplicative of the official capacity claim against Secretary Dixon and must be dismissed. See, e.g., Heywood v. Dixon, 2024 WL 3676386 (N.D. Fla. Aug. 2, 2024) (dismissing officialcapacity claims against two defendants as duplicative of official-capacity claims against another defendant when all three defendants were agents of the Florida Department of Corrections) (citing Busby v. City of Orlando, 931 F. 2d 764, 776 (11th Cir. 1991)).
Accordingly:
1. The official-capacity claims against Sabatier-Smith and T. Bowden are dismissed as duplicative. This action will proceed solely as to Plaintiff's claim against Secretary Dixon in his official capacity.
2. Service of the second amended complaint will be ordered by separate order.
ORDERED in Tampa, Florida, on November 25, 2024.
Charlene Edwards Honeywell Charlene Edwards Honeywell United States District Judge
Copy to: Plaintiff, pro se 2
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Kentucky v. Graham, 473 U.S. 159 (U.S. 1985)
- Busby v. City OF Orlando, 931 F.2d 764 (11th Cir. 1991)
- Owens v. Fulton Cnty., 877 F.2d 947 (11th Cir. 1989)