Snyder v. Trepagnier
142 F.3d 791 (5th Cir. 1998)
Holding
The city was not liable under Monell for the shooting of a fleeing suspect because the plaintiff failed to establish deliberate indifference or a causal link between the city's hiring, screening, or stress management policies and the constitutional violation; the officer was entitled to qualified immunity because the jury could reconcile findings of excessive force and qualified immunity based on the officer's reasonable but mistaken belief the suspect was armed.
What This Case Is About
James Snyder was shot in the back by New Orleans police officer Sidney Trepagnier while fleeing on foot through swamps after a high-speed chase. The shooting left Snyder paralyzed from the waist down. A jury found Trepagnier committed a constitutional violation but was entitled to qualified immunity, and that the City of New Orleans was liable under Monell. The Fifth Circuit reversed the city’s liability and affirmed the officer’s qualified immunity.
The Facts
Trepagnier was pursuing Snyder through swamps when he shot Snyder in the back, paralyzing him from the waist down. The parties disputed whether Snyder had a gun — Trepagnier testified he saw Snyder holding a small pistol, while Snyder claimed he was unarmed and stuck in the mud when he was shot. No gun was ever recovered despite an exhaustive search.
The jury found Trepagnier violated Snyder’s constitutional rights but was protected by qualified immunity. The jury also found the city liable under Monell but Trepagnier did not commit assault and battery. The jury awarded $1,964,000 in medical expenses but $0 for pain and suffering.
Snyder had alleged three municipal policies: deficient hiring and screening, a “code of silence” fostering violence, and failure to train officers in stress management with no “early warning system” for stressed officers.
What the Court Decided
The Fifth Circuit reversed the city’s liability, applying the “rigorous requirements of culpability and causation” from Board of County Commissioners of Bryan County v. Brown.
On hiring/screening, Trepagnier’s only blemishes were admitting to stealing a jacket and smoking marijuana—nonviolent offenses insufficient to make a shooting the “plainly obvious consequence” of hiring him.
On the code of silence, the only evidence was a single prior incident six years earlier and expert testimony. The court found this insufficient, distinguishing the extreme facts of Grandstaff v. City of Borger.
On stress management/failure to train, expert testimony suggested Trepagnier’s hand injuries indicated a quick temper and that an early-warning system might have caught this. But the court found no evidence of a pattern of stress-related constitutional violations, no evidence the city knew of high stress levels, and no causal connection between the absence of a stress program and Snyder’s injury. Expert opinion alone cannot establish municipal “fault.”
The court affirmed qualified immunity, holding the jury’s answers were reconcilable: Trepagnier may have used excessive force (Snyder was unarmed) but reasonably believed Snyder was armed, constituting a “reasonable but mistaken” factual perception.
Why This Case Matters for Your § 1983 Case
Expert testimony alone is not enough for Monell. An expert’s opinion that a city’s practices fell short of “national standards” does not establish the deliberate indifference required for municipal liability without supporting facts showing the city’s bad motive.
Pattern evidence is critical. To prove failure to train, you generally must show a pattern of similar constitutional violations—not just one incident. A single shooting, without more, cannot establish that the city was deliberately indifferent.
Excessive force and qualified immunity can coexist. A jury can find that an officer used excessive force (because the suspect was actually unarmed) while also finding qualified immunity (because the officer reasonably believed the suspect was armed). This reflects the distinction between objective reality and the officer’s reasonable perception.
Hiring claims require strong causal links. Under Bryan County, the connection between an applicant’s background and the specific constitutional violation must be “strong.” Minor, nonviolent offenses on an application do not make a violent incident the “plainly obvious consequence” of hiring.
Key Takeaway
Holding a city liable for an officer’s use of force requires far more than showing the officer committed a constitutional violation. You must identify a specific policy or custom, prove the city was deliberately indifferent to known risks, and establish a direct causal link between the policy and your injury. Expert testimony about “national standards” without factual evidence of the city’s knowledge and deliberate inaction will not carry the day.