Danny Trey Crossland v. Heather Patterson, et al.

Summary

This Report and Recommendation addresses a pro se prisoner’s 42 U.S.C. § 1983 claims alleging deliberate indifference to medical needs by personnel associated with the Vernon Parish Sheriff’s Office. The court concludes that the claims, arising from incidents in October 2023 and filed in September 2025, are barred by Louisiana’s applicable one-year prescriptive period. It recommends dismissal with prejudice.

Holdings

1. A district court may dismiss a § 1983 action sua sponte during screening when the complaint itself clearly establishes that the claims are barred by the applicable limitations period.
2. Louisiana's one-year prescriptive period applied to Crossland's claims because the alleged incidents occurred in October 2023, before Louisiana's two-year limitations period became applicable to incidents occurring on or after July 1, 2024.

Questions Presented

1. Whether the complaint was subject to dismissal under the in forma pauperis screening statute.
2. Whether Crossland's § 1983 claims were barred by Louisiana's one-year prescriptive period when the alleged constitutional violations occurred in October 2023 and the complaint was filed on September 16, 2025.

Disposition

dismissed