Stallworth v. Bryant, No. 18-60487 (5th Cir. 2019)Annotate this Case
Plaintiffs filed suit challenging Mississippi Senate Bill 2162, claiming that it violated the Fourteenth Amendment's Equal Protection Clause and the equal protection component of the state constitution. The district court affirmed the magistrate judge's grant in part of plaintiffs' motion to enforce subpoenas on eight state legislators, ordering them to produce a privilege log and any relevant information previously shared with third parties.
The Fifth Circuit held that, to the extent the order required the Legislators to comply with Request 3 in the subpoenas issued by the JMAA plaintiffs, the district court abused its discretion in ordering the Legislators to comply with a production order unrelated to those plaintiffs' claims. The court also held that, because the individual plaintiffs were without standing to pursue the equal protection claim, the district court lacked jurisdiction to enforce their subpoenas. Accordingly, the court vacated and remanded with instructions to dismiss without prejudice, for want of jurisdiction, the equal protection claim of the intervenors' complaint.