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EFTA01900688 | EFTA01900746 defendants would stretch to suggest as much, given that none of these defendants (only Governor Jindal, who was dismissed by this Court's Order and Reasons, see Doe v. Jindal, No. 11-388, 2011 WL 39250425 (E.D. La. Sept. 7, 2011) invoked sovereign immunity in Doe I. Moreover, this Court previously observed that these defendants have the authority to enforce the registry law in Doe I: "there seems little doubt that the defendants are responsible for administering and enforcing the sex registry 15 all the relief the plaintiffs seek is prospective, and they insist that plaintiffs fail to allege an ongoing violation of federal law because Act 402 changed everything. "[I]n determining whether the doctrine of Ex parte Young avoids an Eleventh Amendment bar to suit, a court need only conduct a 'straightforward inquiry into whether [the] complaint alleges an ongoing violation characterized as of federal law prospective." and seeks Stewart, 131 relief S.Ct. properly at 1639 (quoting Verizon Md. Inc. v. Public Sew. Comm'n of Md., 535 U.S. 635, 645 (2002)). The plaintiffs' lawsuit satisfies this inquiry: they allege an ongoing violation of federal law pursuant to § 1983 (by alleging that the defendants continue to fail to remedy the Equal Protection violation conduct focused in Doe I). They do also seek relief that is indeed prospective in nature: declaratory relief that their continued subjection to sex offender registration and notification requirements violates the Equal Protection clause; that they be removed from the registry; and that the records law...[t]his places the defendants among those who contribute to the plaintiffs' harm." See Doe I, 851 F. Supp. 2d 995, 1004 (E.D. La. 2012). Defendants did not appeal this Court's ruling in Doe i. It is also noteworthy that, during oral argument, counsel for defendants conceded that the nine plaintiffs in Doe I were provided relief in accordance with this Court's Judgment (including by being removed from the sex offender registry and issued new licenses without the "SEX OFFENDER" designation) through cooperation amongst various defendants in their official capacities; the same defendants named in this lawsuit. 16 documenting that they are sex offenders be expunged.10 IiI. Standing The defendants next urge this Court to resolve another threshold issue: the Court must be satisfied that each of the three plaintiffs have standing to challenge the continued registration requirement imposed on individuals convicted of violating Louisiana's Crime Against Nature by Solicitation statute. Like they did in Doe i, the defendants vigorously attack the plaintiffs' standing. Article III of the Constitution commands that a litigant must have standing to invoke the power of a federal court. See Nat'l Fed'n of the Blind of Texas, Inc. v. Abbott, 647 F.3d 202, 208 (5th Cir. 2011). The doctrine of standing requires that the Court satisfy itself that "the plaintiff has 'alleged such a personal stake in the outcome of the controversy' invocation of federal-court jurisdiction." as See to warrant his Summers v. Earth Island institute, 555 U.S. 488, 493 (2009); see also Doe v. Beaumont Indep. Sch. Dist., 240 F.3d 462, 466 (5th Cr. 2001Xciting Warth v. Seldin, 422 U.S. 490, 498, 95 S.Ct. 2197, 45 L.Ed.2d 343 10 In fact, the plaintiff's in Doe I sought the same relief which the defendants did not then argue was retrospective in nature. Plaintiffs here thus characterize defendants' sovereign immunity argument as frivolous. It seems, at best, a submission of tortured reasoning, and offers an unnaturally restrictive view of the Court's decision in Doe I regarding defendants' conduct when measured by Equal Protection doctrine. 17 (1975)). "Standing to sue must be proven, not merely asserted, in order to provide a concrete case or controversy and to confine the courts' rulings within our proper judicial sphere." Doe v. Tangipahoa Parish School Bd., 494 F.3d 494, 499 (5th Cir. 2007) (noting that "[n]o amount of creative inferences from the pretrial order or 'stipulations' can overcome [the necessary proof in the record required to show standing]" and that the Board's failure to contest standing cannot create jurisdiction because standing is not subject to waiver by the parties). To establish standing, the plaintiffs must EFTA_R1_00329774 EFTA01900746 Epstein Web iOS app on the App Store.
March 14, 2026 at 10:35 AM