Cripps v. Louisiana Dep't of Agriculture & Forestry, No. 15-30524 (5th Cir. 2016)Annotate this Case
Plaintiffs, brothers who worked in the pest control industry, filed suit against LDAF and LDAF's Assistant Director David Fields, in his individual capacity, alleging various claims related to the hearings before LDAF for violations of Louisiana's Pest Control Laws, La. Stat. Ann. 3:3363. The court concluded that plaintiffs failed to establish sufficient evidence to demonstrate that defendants retaliated against them for complaining before the Commission and others. Because summary judgment was proper as to plaintiffs' First Amendment claims, summary judgment is also proper as to plaintiffs' state law claims. The court also concluded that summary judgment was properly granted as to the substantive due process claims. In this case, although plaintiffs may have a protected interest in being free from arbitrary state action not rationally related to a state purpose, they do not have a constitutional right to violate rules and regulations of the Louisiana Pest Control law. The record establishes a substantial basis for defendants’ actions and precludes any inference that such actions were arbitrary. Because Louisiana courts have found the due process protections in the Louisiana Constitution to be coextensive with the protections of the Fourteenth Amendment, the same determination applies to plaintiffs’ state law claims. Finally, the court concluded that plaintiffs' Eighth Amendment claim fails because, assuming that the Excessive Fines Clause applies in this instance, the record indicates that each of plaintiffs' offenses resulted in fines that do not exceed the limits prescribed by the statute authorizing it. Under the facts established in the summary judgment record, plaintiffs' claims against David Fields failed. Accordingly, the court affirmed the judgment.