This page provides public access to court filings concerning Barrow County Officials. It includes motions, orders, timelines, and related case documents.
The underlying state-court dispositions and procedural facts referenced in this complaint are documented in official court records and established by final lower-court rulings. Document 62 relies on those undisputed lower-court determinations while presenting separate federal constitutional claims and requests for relief to the United States District Court.
Plaintiff’s Response in Opposition to Defendants’ Motion to Dismiss - Document 67
Court: United States District Court for the Northern District of Georgia, Gainesville Division
Case: Lamont Howard v. Kyle William Sharry, Janie Jones, Denise Fuller, and Robert M. Gardner Jr.
Case number: 2:25-cv-00040-SCJ
Document: 67
Filed: March 16, 2026
Filed by: Lamont Howard, plaintiff proceeding without an attorney
Length: 7 pages
This filing is the plaintiff’s response opposing the County defendants’ request to dismiss the Second Amended Complaint.
The plaintiff argues that the Second Amended Complaint provides sufficient factual allegations and is not a shotgun pleading. The response also argues that Younger abstention does not apply, that municipal liability has been adequately alleged, that sovereign immunity does not bar the asserted federal constitutional claims, and that qualified immunity should not result in dismissal at the pleading stage.
The plaintiff asks the court to deny the motion to dismiss and permit the case to proceed to discovery.
This document presents the plaintiff’s arguments in opposition to dismissal. At this stage of the litigation, the court must accept the operative complaint’s well-pleaded factual allegations as true and draw reasonable inferences in the plaintiff’s favor when deciding the motion to dismiss.