Degenhardt v. Bintliff

What This Case Is About

Degenhardt v. Bintliff is a 2024 Fifth Circuit decision addressing traffic stops, vehicle searches, vehicle impoundment, and First Amendment retaliation. Two brothers were pulled over, searched, cited, and had their car impounded — allegedly in part because they laughed and smirked at the officers. The court found the brothers stated a claim that the initial stop lacked reasonable suspicion but held the officers entitled to qualified immunity on the impoundment and retaliation claims.

The Facts

On March 20, 2022, Marc Degenhardt (age 18) was driving his parents’ black Dodge Challenger with his brother Augustus (age 20) as passenger. Both cars — the Challenger and a blue Dodge Charger — were stopped at a traffic light waiting to turn left. When the light turned green, both vehicles turned and merged into a single lane.

Lt. Phillip Bintliff of the Corpus Christi Police pulled the Challenger over, accusing Marc of “burning out” and racing the Charger. The Degenhardts denied doing anything wrong and alleged they had simply driven normally. The Challenger was known to be unusually loud, even by the dealership’s admission.

During the stop, Bintliff shined a flashlight into the vehicle and observed an opened cardboard box containing White Claw Hard Seltzers. After learning the brothers were under 21, the officers ordered the Degenhardts out of the car. Cisneros then conducted a search.

Throughout the encounter, the brothers allegedly laughed and smirked, which frustrated the officers. According to the complaint, Cisneros told Bintliff: “I’ll write up the reckless driving… and we’ll impound [the vehicle] because they were laughing.” The officers impounded the Challenger, cited both brothers for possessing alcohol as minors, gave Marc a reckless driving warning, and dropped them at a convenience store. The charges were later dropped.

What the Court Decided

The Fifth Circuit affirmed in part, reversed in part, and remanded:

Traffic stop (reversed): The court found the Degenhardts adequately alleged Bintliff lacked reasonable suspicion. Taking their well-pleaded facts as true — both cars drove normally, neither raced — there was no articulable basis for the stop beyond the Challenger’s loudness, which wasn’t clearly linked to a muffler violation.

Vehicle search (affirmed): The White Claws were in plain view, and after confirming the brothers were underage, officers had probable cause to search. The search was lawful regardless of whether the initial stop was valid.

Vehicle impoundment (qualified immunity): Officers failed to articulate a community-caretaker justification for impounding. They didn’t arrest the brothers, and probable cause to arrest doesn’t automatically authorize seizing property. However, this legal principle wasn’t clearly established, so qualified immunity applied.

First Amendment retaliation (qualified immunity): Despite Cisneros’s recorded statement about impounding “because they were laughing,” the officers had probable cause for the citations, which defeated the retaliation claims as to the citations. On the impoundment, while the officers lacked a lawful basis, existing precedent didn’t clearly address whether probable cause to arrest defeats a retaliatory seizure of property claim. Qualified immunity applied.

Judge Graves dissented on the retaliation claim, arguing it was clearly established that officers cannot punish people for disrespectful speech.

Why This Case Matters for Your § 1983 Case

This case is rich with lessons:

• Well-pleaded facts control at dismissal. The district court erred by crediting the officer’s account over the plaintiffs’ allegations. At the motion-to-dismiss stage, the plaintiff’s version prevails.

• Plain view doctrine operates independently. Even if a stop is unlawful, observations made in plain view may provide independent probable cause for a search.

• Probable cause to arrest ≠ authority to seize property. Under the community caretaker exception, impounding a vehicle requires its own justification. Simply having probable cause to arrest the driver is not enough if the driver is not actually arrested.

• Retaliation claims face the Nieves hurdle. Under Nieves v. Bartlett, probable cause generally defeats a retaliatory arrest claim. But as Gonzalez v. Trevino shows, comparator evidence may provide an alternative path.

• Officers’ own statements can establish retaliatory motive — but qualified immunity may still apply if the relevant legal principles are unsettled.

Key Takeaway

Degenhardt v. Bintliff shows that officers cannot stop vehicles without reasonable suspicion, even if the car is loud. However, once contraband is spotted in plain view, the unlawfulness of the stop does not prevent a lawful search. And while officers’ candid admissions of retaliatory motive are powerful evidence, qualified immunity may still shield them if the specific legal rule they violated was not yet clearly established.