Eugene v. Alief Independent School District

What This Case Is About

Beryl Eugene, a Black mother, went to her son’s school to complain about what she believed was racially motivated placement of her son in special education. When she tried to leave the conference room — she says to find a restroom — a school principal and security officer physically confronted her, tackled her, choked her, and arrested her. She was charged with assault on a police officer but acquitted. She then sued the school district, principal, and security officer under 42 U.S.C. § 1983. The Fifth Circuit held that false arrest, malicious prosecution, and bodily harm are actionable under § 1983, reversing in part the district court’s grant of summary judgment.

The Facts

Eugene’s son attended Landis Elementary School in the Alief Independent School District during the 1990–91 school year. On September 28, 1990, Eugene attended a meeting at the school to voice complaints about her son’s placement in special education, which she believed was racially motivated, and about mishandling of his medication.

During the meeting, Eugene decided to withdraw her son and asked that someone bring him from class. A counselor left to get the boy. Eugene then said she needed a restroom and left the conference room, heading down a hallway. She claims she didn’t know the hall led to classrooms. Principal Paula Conley told security officer R.F. Griffin to stop Eugene. Conley pushed Eugene; Griffin then pushed her, tripped her, pushed her to the ground, and began to choke her. Eugene bit Griffin’s hand to make him release her neck. Griffin then told her she was under arrest and handcuffed her. Eugene was not aware Griffin was a police officer during the confrontation.

Eugene was charged with assault on a police officer. A jury found her guilty, but the state district judge entered a verdict of not guilty as a matter of law.

What the Court Decided

The Fifth Circuit reversed in part and affirmed in part. Crucially, the court confirmed that malicious prosecution, false arrest, and bodily harm are all actionable under § 1983 because they violate the Fourth and Fourteenth Amendments. The district court had erroneously held these were not cognizable § 1983 claims.

On qualified immunity for the individual defendants — Conley and Griffin — the court reversed summary judgment, finding genuine issues of material fact about whether their conduct was objectively reasonable. A reasonable officer would know that physically attacking a parent who was merely walking down a hallway violated clearly established constitutional rights.

However, the court affirmed summary judgment for the school district under Monell, because Eugene failed to show that an official policy or custom of the district caused her injuries. An isolated incident involving individual employees is not enough to establish municipal liability.

Why This Case Matters for Your § 1983 Case

This case is important for several reasons. First, it confirms that false arrest, malicious prosecution, and physical assault by government officials are all proper bases for § 1983 claims — they are constitutional violations, not merely state law torts. Second, the acquittal (and particularly the judgment of acquittal as a matter of law) is significant for the favorable termination element of a malicious prosecution claim.

Third, the case illustrates the distinction between individual and municipal liability. Even when individual officers clearly violated someone’s rights, the municipality or school district escapes liability unless you can prove a policy or custom was the moving force behind the violation.

Key Takeaway

Government officials who physically assault, falsely arrest, and maliciously prosecute someone can be held personally liable under § 1983 — these are constitutional violations, not just torts. But to hold the employing entity liable, you must show an official policy or custom caused the violation. An isolated incident of misconduct by employees, no matter how egregious, does not establish Monell liability against the government entity.