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Section 1983 Conspiracy Cases

12 cases in the library

A conspiracy claim requires an agreement to violate rights and an actual violation. Courts dismiss conspiracy counts that infer agreement from the fact that officers were present together or work for the same department. These cases show what facts have supported the inference and how the intracorporate conspiracy doctrine has been applied.

Cases, newest first

Young v. City of Irving

No. 3:23-CV-1423-D (N.D. Tex. 2024) · Sep 12, 2024

Granted motions to dismiss pro se plaintiff's § 1983 claims against the City of Irving and police officers but granted leave to replead; held that video evidence contradicting the plaintiff's allegations of unlawful arrest and excessive force entitled officers to qualified immunity, and that municipal liability claims based on conclusory allegations of policy or custom failed.

Bevill v. Wheeler

103 F.4th 363 (5th Cir. 2024) · Jun 5, 2024

On remand from the initial appeal, the Fifth Circuit addressed additional qualified immunity issues in the First Amendment retaliation conspiracy case, further defining the standards for § 1983 conspiracy claims against public officials who retaliate against government employees for protected speech.

Spiller v. Harris County

No. 22-20123 (5th Cir. 2023) · Jan 1, 2023

Reaffirmed that employees of the same legal entity cannot conspire among themselves under § 1983 and that municipal liability requires identification of an official policy or custom, not merely individual officer misconduct.

Bevill v. Fletcher

26 F.4th 270 (5th Cir. 2022) · Feb 11, 2022

A police captain's First Amendment retaliation claim under § 1983 survived a motion to dismiss where the complaint plausibly alleged that a judge, district attorney, and sheriff conspired to have him fired in retaliation for signing an affidavit critical of their professional relationships.

Spiller v. Harris County, Texas

No. 21-20574 (5th Cir. 2022) · Jan 1, 2022

Employees of the same municipal entity cannot conspire among themselves for purposes of a § 1983 conspiracy claim because a single legal entity cannot conspire with itself.

Collins v. Bauer

No. 3:11-CV-00887-B (N.D. Tex. 2012) · Jan 23, 2012

A motorcyclist's § 1983 excessive force and conspiracy claims against Dallas police officers survived motions to dismiss where the complaint alleged officers chased the plaintiff in violation of department policy, rammed his motorcycle, and beat him while he lay spread-eagled on the ground.

Swilley v. City of Houston

457 F. App'x 400 (5th Cir. 2012) · Jan 1, 2012

Employees of the same legal entity cannot conspire among themselves under § 1983; the City of Houston is a single legal entity and its employees cannot form a conspiracy as a matter of law.

Walters v. McMahen

795 F. Supp. 2d 350 (D. Md. 2011) · Jul 14, 2011

Dismissed civil RICO class action alleging that corporate employees conspired to hire illegal immigrants to depress wages, holding that the intracorporate conspiracy doctrine bars conspiracy claims among employees of the same corporation acting within the scope of their employment.

Hale v. Townley

45 F.3d 914 (5th Cir. 1995) · Feb 21, 1995

Government officials who conspire with private parties to violate constitutional rights can be held liable under § 1983; the private party can also be liable if they acted jointly with state actors under color of law.

Hilliard v. Ferguson

30 F.3d 649 (5th Cir. 1994) · Sep 8, 1994

A school board's policy of individually reviewing the circumstances of each applicant's felony conviction before making employment decisions was rationally related to the legitimate interest of protecting schoolchildren and did not violate equal protection; a school board cannot conspire with its own employees under § 1985(3).

Lynch v. Cannatella

810 F.2d 1363 (5th Cir. 1987) · Feb 27, 1987

Even excludable aliens physically present in the United States are entitled to due process protection from gross physical abuse by state or federal officials — and harbor police who subjected Jamaican stowaways to beatings, hosing, forced labor, and drugging could not claim qualified immunity.

Nelson Radio & Supply Co. v. Motorola, Inc.

200 F.2d 911 (5th Cir. 1952) · Dec 17, 1952

A corporation cannot conspire with its own officers and agents under Section 1 of the Sherman Act; discussions among those managing a single corporation about its business policies do not constitute a conspiracy in restraint of trade.

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