Steven Bell v. State of Louisiana, et al.

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA STEVEN BELL CIVIL ACTION VERSUS STATE OF LOUISIANA, ET AL. NO. 24-00982-BAJ-SDJ RULING AND ORDER On March 17, 2026, the Magistrate Judge issued a Report and Recommendation (Doc. 9, the “Report”) recommending that the Court dismiss Plaintiff’s federal claims with prejudice as legally frivolous and for failure to state a claim upon which relief may be granted pursuant to 28 U.S.C. §§ 1915(e) and 1915A.

The Report further recommends that the Court decline to exercise supplemental jurisdiction over potential state law claims and close this case. (Doc. 9 at 4). No party objected to the Report.

Plaintiff filed this suit under 42 U.S.C § 1983 against the State of Louisiana and state officials for allegedly violating his constitutional rights during his criminal prosecution and conviction in state court. The sole form of relief sought by Plaintiff is release from confinement.

The Magistrate Judge recommends dismissal of Plaintiff’s federal claims because Plaintiff’s request for release from confinement is not cognizable under Section 1983. See Wilkinson v. Dotson, 544 U.S. 74, 78 (2005) (“[A] prisoner in state custody cannot use a § 1983 action to challenge ‘the fact or duration of his confinement.’”). The Report further recommends that while a court may construe a Section 1983 case as one brought under habeas statute 28 U.S.C. § 2254, it is improper to do so here because Plaintiff did not exhaust his state court remedies before appearing before this Court. Further, the Report recommends that leave to amend is not warranted because Plaintiff has pleaded his best case but still fails to state a claim. Finally, the Magistrate Judge recommends that if the Court dismisses all of Plaintiff’s federal claims, it is appropriate under 28 U.S.C. § 1367 for the Court to decline to exercise supplemental jurisdiction over any potential state law claims Plaintiff may have.

After the Magistrate Judge issued the Report and Recommendation, Plaintiff filed a motion requesting his immediate release from custody because of alleged flaws during his state indictment proceedings. (Doc. 10). The facts stated in the Motion have been considered, but they do not change the analysis of the Report and Recommendation.

After considering Plaintiff’s Complaint (Doc. 1), the Report and Recommendation (Doc. 9), and the entirety of the record, the Court APPROVES the Magistrate Judge’s Report and Recommendation and ADOPTS it as the Court’s opinion in this matter.

Accordingly, IT IS ORDERED that Plaintiff’s federal claims are DISMISSED WITH PREJUDICE as legally frivolous and for failure to state a claim upon which relief may be granted pursuant to 28 U.S.C. §§ 1915(e) and 1915A.

IT IS FURTHER ORDERED that the Court declines to exercise supplemental jurisdiction over any potential state law claims.

IT IS ORDERED that Plaintiffs subsequent Motion for Dismissal (Doc. 10) is DENIED AS MOOT.

Judgment will be entered separately.

Baton Rouge, Louisiana, this day of April, 2026 JUDGE BRIAN A. I UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA