Lewis v. Williamson County

Background

Scott Phillip Lewis proceeded without a lawyer and without paying the filing fee. He alleged that the defendants violated his rights. In an earlier order, the court dismissed his claim under the Americans with Disabilities Act for failure to state a claim because he had not alleged facts suggesting that the defendants denied him access to a public accommodation.

The court then ordered Lewis to explain why his claims under 42 U.S.C. § 1985(3), a statute addressing certain conspiracies to deprive people of federal rights, should not be dismissed as time-barred. In an August 25, 2025 order, the court assumed for purposes of that order that equitable tolling applied, meaning that the filing deadline could be extended for fairness reasons. Even with that assumption, the court dismissed the Section 1985(3) claim for failure to state a claim and allowed 30 days to replead.

Lewis filed an amended complaint on September 24, 2025. He added three members of the Vandegrift Texas Lacrosse Booster Club, but the amended complaint was otherwise nearly identical to the original complaint.

Court’s analysis

The court had previously found that Lewis’s allegations about a conspiracy involving a Texas city and county, media companies, and a Texas booster club were conclusory and vague. In the amended complaint, Lewis alleged that the defendants “worked in tandem” to discredit him and believed that his rights could be violated without consequence.

The court concluded that this statement still did not provide a factual basis showing that the named defendants participated in a specific conspiracy to deny him a specific federal right. Because the court had already dismissed the Americans with Disabilities Act claim and Lewis did not identify another federal right that the defendants violated, the court held that he could not establish a Section 1985(3) conspiracy claim. The court therefore dismissed the Section 1985(3) claim for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii), the provision requiring dismissal of certain claims filed without paying the filing fee.

Disposition

The court dismissed Lewis’s amended complaint. The opinion does not state that the dismissal was with or without prejudice. The court directed the clerk to terminate any motions and enter a civil judgment. It also certified that any appeal would not be taken in good faith and denied Lewis permission to appeal without paying filing fees. Judge Laura Taylor Swain signed the order.