This case is based on the fact that State and Federal officials failed to follow the law in a conspiracy to cover up the murder of my son. The Director of the Louisiana State Board of Medical Examiners intentionally lied to inflict emotional distress upon me when he sent me a letter stating that a thorough investigation into the illegal use of controlled substances on my son was done, and that there was no violation of the Louisiana Medical Practice Act. The Director knew the letter was all lies made with the sole intention to injure me by denying me a sense of closure and justice in the brutal murder of my baby. The action by the Director to cover up the murder of my baby would “Shock the Conscience” of any decent person. The action by the Director to intentionally lie to cover up the murder of my son is Official Misconduct, which violates my 14th Amendment Rights. The Medical Practice Act clearly states that it is a violation to use a controlled substance without legitimate medical justification, which mean the drugs must be used to help my son. To this date no one has showed us that the drugs benefited my baby, only lies, no documentation. The Director knew for a fact that the drugs were used with the intent to kill my son which is the reason why the Director refuses to produce documentation to prove the drugs were used legally. This is a clear case of “Shock the Conscience” for anyone that would cover up the murder of an innocent baby.

All facts asserted in the murder of Dion Henry is true and accurate. If anyone doubt the truth and accuracy of the facts is welcome to prove us wrong in any open forum.

The doctors gave my 2 year old son an undocumented combination of controlled substances, and when we asked the doctors to show us where the controlled substance laws were followed, the doctors asked a judge to dismiss our case, which he did, after we clearly disputed the lies from the doctors, and despite the fact the doctors did not produce documentation to show the judge that the laws were followed. The judge was biased against me for believing lies from the doctors when the law clearly says that the doctors must document all medical treatment. The judge violated my right to dispute authenticity, in violation of FRE 902, and my Due Process Rights.

Doctors Vincent Adolph and Richelle Monier of Ochsner Health, in New Orleans, injected my two-year-old son with an undocumented, lethal combination of Ativan, Phenobarbital, and Versed, with the sole purpose to damage my son’s brain in order to harvest his organs. The doctors then told the Louisiana Organ Procurement Agency to hide information from me concerning my deceased son. Why hide the truth?

We paid an attorney in Louisiana $5000.00 to represent us, but he took our money and ​dropped off the case, so we had to proceed Pro Se. We filed suit against the doctors in search of ​answers as to why my son was given a combination of three central nervous system ​depressants without my knowledge or consent. Court records will show the attorneys from ​Adams and Reese knowingly and willfully lied to cover up the murder of my baby. The doctors ​did not provide their attorneys any proof, as required by law that my son was treated for ​emergent seizures. The attorneys know, by law, that the burden of proof falls on the doctors to ​document and justify the emergent treatment was necessary, and any attempts made to ​contact the parents. The attorneys for the doctors knowingly and with malice lied to cover up ​the fact the doctors committed assault and battery with intent to kill my 2 year old son, by ​injecting him with a lethal combination of controlled substances, that as of today no one has ​proven the drugs were used for a legal and legitimate medical purpose. If the doctors truly ​treated my son for emergent seizures, the same law that gave them the right to treat my son ​for emergent seizures required the doctors to document and justify the treatment was ​necessary, and if the doctors followed the law, their attorneys would have documentation from ​the doctors proving my son was treated for emergent seizures. All the attorneys have is lies ​from the doctors, no documented proof as required by the law in LA Rev Stat §40:1299.54.

We also filed a complaint against the doctors, with the Louisiana State Board of Medical Examiners, for an illegal use of controlled substances causing the death of my son. The Board sent us a letter stating that a thorough investigation of our complaint was done, and that there was no violation of the Medical Practice Act found. The Board knowingly and willfully lied by saying there was no violation of the Medical Practice Act. LA Title 46, XLV §6923 states, “Any violation of or failure of compliance with the provisions of this Subchapter, §§6915-6923, shall be deemed a violation of R. S. 37:1285 (A)(6). Section 1285 is a part of the Medical Practice Act, which defines the legal use of controlled substances. Our complaint with the Board alleged the doctors violated Section 1285 by administering a combination of controlled substances to my son without my consent. L A Title 46, XLV §6921, (A)(4) clearly states that Informed Consent shall be obtained before any controlled substances are administered. The only way a doctor can treat anyone without consent is where an emergency exists, which the doctors did lie by saying my son was treated for emergent seizures. The State Board of Medical Examiners and doctors have the same attorneys in conspiracy to cover up the murder of my son. The attorneys and the Board both lied by saying my son was treated for emergent seizures, without any documentation from the doctors to prove my son was treated for emergent seizures. By law, the burden of proof falls on the doctor to document to prove an emergency existed, and the doctors must document all attempts made to contact the parents. By law, the Board and the attorneys must have the burden of proof document from the doctors, which is the only way to prove the Medical Practice Act was not violated.

Instead of the Board proving to us that the laws were followed, they chose to fraudulently conceal the results of the investigation to conceal the fact they lied to cover up the murder of my son, which led us to filing suit against the Director of the Board, requesting documents to simply show us that the law was followed in the use of controlled substances on my son. The Director refused to show me the results of the investigation. The doctors and the Director hired the same attorneys, in an attempt to cover up the murder of my son, with only lies and no documentation. Our federal suit against the Director was based on the fact that the Board said, without proof, that all laws were followed in the use of controlled substances on my son. We have my son’s medical records, and nowhere in the records does it show any emergent seizures treatment, nor does it show that my son was ever diagnosed with seizures, as required by LA Title 46 XLV §6921 (A)(2), which clearly says a medical diagnosis shall be established and fully documented in the patient’s medical records.

The judge further violated my Due Process Rights by dismissing my suit for failure to state a claim ​that is plausible on its face, pursuant to Rule 12 (b)(6). The face of my complaint is based on the ​concealment of controlled substances. The judge never mentioned controlled substances in his ​ruling. The law says when ruling on a 12 (b)(6) motion the court must consider the complaint in its ​entirety, as well as other sources courts ordinarily examine when ruling on Rule 12 (b)(6) motions to ​dismiss, in particular, documents incorporated into the complaint by reference, and matters of which ​a court may take judicial notice. The face of my complaint is based on the results of the investigation. ​The judge illegally dismissed my case by not considering the entire complaint, particularly the results ​of the investigation, which is entirely relevant to my complaint. We alleged in the complaint that, “the ​Director used his position to fraudulently conceal relevant facts in the illegal use of controlled ​substances that caused the death of my son, in violation of my 14th Amendment Rights to Due ​Process, all because I’m Black. Those allegations are not only plausible, but are well known facts. The ​allegation that the Director is lying to cover up the murder my son, “States a Claim” because it is a ​violation of the 14th Amendment for a State Official to commit Official Misconduct. The judge violated ​my rights by ruling that I did not have the right to see the results of the investigation concerning my ​deceased son. The judge was racially biased against me for not considering the results of the ​investigation, when in fact he knows extrinsic evidence, such as the results of the investigation, is ​considered part of the complaint when incorporated in the pleading.

The fact that the Board says one thing, and the medical records show something totally different, ​creates a factual dispute. We have disputed the medical treatment of my son all along, including in our ​suit against the Director. Article III, Section 2, Clause 1, of the Constitution, gave me the right to have my ​dispute resolved in Federal Court. The judge violated Article III, by dismissing my case while there is a ​clear Case and Controversy. By law, pursuant to Federal Rules of Evidence 902(4), guarantees that the ​contents of the investigation is true and correct. By law, the contents of the investigation is self ​authenticated, and the law in Rule 902 gave me the right to dispute the contents of the investigation. ​Federal Judge Jay C. Zainey violated my Due Process Rights by dismissing my suit after I clearly disputed ​the authenticity of the investigation. Federal Rules of Evidence 902 says, “in no instance is the opposite ​party foreclosed from disputing authenticity.” The contents of the investigation is authenticity. Judge ​Zainey knowingly and willfully foreclosed me to keep the false investigation and the murder of my son ​covered up. The judge intentionally violated my Due Process rights to dispute the findings of the ​investigation.

The results of the investigation is integral to the complaint, and was relied heavily upon when the ​complaint was framed. My complaint is totally centered on the results of the investigation, and was cited ​throughout the complaint. The judge know the results of the investigation will prove my son was ​murdered, and not treated for emergent seizures. The judge’s ruling was illegally made to cover up the ​murder of my son, and to cover up the lies by the Director and the attorneys at Adams and Reese.

Appeals are ineffective in the 5th Circuit, because the Justices cares more about the 11th Amendment ​than they do about the 14th Amendment. The Justices basically ruled that the State can make and ​enforce laws that protect State Officials who commit Official Misconduct by lying that a thorough ​investigation was done without providing any proof to prove that an investigation was actually done. ​State Officials, including Jeff Landry, intentionally lied to cover up the murder of my 2 year old baby.

The Mother and Family of Dion Henry