Jail and Prison Cases

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.

Gonzalez v. Trevino

602 U.S. ___ (2024) · Jun 20, 2024

A plaintiff can use any objective evidence — not just strict comparator evidence — to show she was arrested when similarly situated individuals not engaged in the same protected speech had not been, thereby satisfying the narrow Nieves exception.

Hughes v. Garcia

101 F.4th 373 (5th Cir. 2024) · May 3, 2024

Officers who filed a false report and warrant affidavit containing reckless misstatements and omissions to arrest a Good Samaritan for felony impersonation of a police officer — while letting the drunk driver go — were not entitled to qualified immunity under the Franks doctrine.

Zavala v. Harris County

No. 22-20611 (5th Cir. 2023) · Nov 21, 2023

Affirmed dismissal of Monell claims against Harris County and grant of qualified immunity to a jailer on excessive force claims arising from use of hog-tie restraints on a pretrial detainee, holding that the use of hog-ties was not clearly established as unconstitutional where the detainee exhibited disorderly and self-injurious behavior.

City of Houston v. Nicolai

No. 01-20-00327-CV (Tex. App.—Houston [1st Dist.] 2023) · Apr 6, 2023

The City of Houston did not establish as a matter of law that its police officer was entitled to official immunity for negligently operating a patrol car, meaning the Texas Tort Claims Act's waiver of governmental immunity applied and the suit could proceed.

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.

Kelson v. Clark

No. 20-10764 (5th Cir. 2021) · Jun 17, 2021

Paramedics who refused to treat a visibly injured, homeless, mentally ill man — instead harassing and laughing at him — were not entitled to qualified immunity on a failure-to-provide-medical-care claim after the man died from untreated head trauma in custody.

Esquivel v. Eastburn

No. SA-20-CV-00377-OLG (W.D. Tex. Apr. 28, 2021) · Apr 28, 2021

A pro se plaintiff's § 1983 claims against state troopers for unlawful arrest, illegal search, and excessive force survived initial screening but were subject to dismissal where the plaintiff failed to state plausible claims against certain defendants.

Hutcheson v. Dallas County

No. 20-10383 (5th Cir. 2021) · Apr 12, 2021

Officers who restrained a man under the influence of drugs were entitled to qualified immunity where their conduct did not violate clearly established law, and a single incident was insufficient to establish failure-to-train liability.

Brown v. Tarrant County

No. 19-10594 (5th Cir. 2021) · Jan 18, 2021

A civilly committed sexually violent predator's § 1983 claims against a county and its sheriff for failure to provide sex offender treatment during a twenty-day jail confinement were properly dismissed where the sheriff was entitled to qualified immunity and no municipal liability claim was stated.

Taylor v. Riojas

592 U.S. 7 (2020) · Nov 2, 2020

No reasonable correctional officer could have concluded it was constitutionally permissible to confine an inmate in cells covered in human waste for six days — qualified immunity denied even without a prior case with identical facts.

Sanchez v. Young County

956 F.3d 785 (5th Cir. 2020) · Apr 22, 2020

Summary judgment for the county on a conditions-of-confinement claim was reversed where evidence showed the jail had a persistent pattern of failing to complete mandatory intake screenings, and a pretrial detainee died of a drug overdose after jailers put her in a cell to 'sleep it off' without completing suicide screening or medical intake forms.

Winfrey v. Rogers

No. 16-20702 (5th Cir. 2018) · Feb 5, 2018

Vacated summary judgment for a deputy who signed arrest warrant affidavits containing material omissions and misstatements, holding that the corrected affidavit would not have established probable cause and that the independent intermediary doctrine did not apply where the grand jury was not presented with all material facts.

Skyy v. City of Arlington

No. 17-10529 (5th Cir. 2017) · Nov 9, 2017

Pro se plaintiffs' § 1983 claims against the city were dismissed because they relied on a respondeat superior theory—that city officers violated city personnel manual policies—rather than identifying a municipal policy or custom that was the moving force behind the alleged constitutional violations.

Ziglar v. Abbasi

582 U.S. 120 (2017) · Jun 19, 2017

The Court severely limited the Bivens implied damages remedy, holding that courts should not extend it to new contexts — and that post-9/11 detention policy claims present such a new context.

Alexander v. City of Round Rock

854 F.3d 298 (5th Cir. 2017) · Apr 18, 2017

Officers were not entitled to qualified immunity on excessive force claims where plaintiff alleged he was forcibly removed from his vehicle, pinned face-down, and had a knee pressed on his neck during a traffic stop despite offering no physical resistance.

Childers v. Iglesias

848 F.3d 412 (5th Cir. 2017) · Feb 9, 2017

A rancher's § 1983 false arrest claim was properly dismissed where the facts alleged in the complaint established that the officer had probable cause to arrest for interfering with police duties, even though the charges were later dropped.

Brooks v. City of West Point, Mississippi

639 F. App'x 986 (5th Cir. 2016) · Feb 11, 2016

Officers were not entitled to qualified immunity on an excessive force claim where, viewing the facts in the plaintiff's favor, the plaintiff was grabbed, slammed against a garage door, and forced to the ground while not physically resisting, but were entitled to qualified immunity on the unlawful arrest claim where arguable probable cause existed for disorderly conduct.

Wafer v. Molina

No. 3:14-CV-0976-M-BH (N.D. Tex. 2014) · Jun 13, 2014

Recommended dismissal of § 1983 false arrest and unlawful detention claims as frivolous under 28 U.S.C. § 1915(e)(2), holding that official-capacity claims against officers are treated as claims against the municipality, that police departments are not suable entities, and that a county jail is not a legal entity capable of being sued.

Ramirez v. Martinez

716 F.3d 369 (5th Cir. 2013) · May 15, 2013

A deputy was not entitled to qualified immunity on excessive force claims where he tased a business owner twice — including once while the owner was handcuffed and lying face-down — during an encounter at the owner's own business; but the deputy had arguable probable cause for the arrest.

Alford v. State

358 S.W.3d 647 (Tex. Crim. App. 2012) · Jan 25, 2012

An appellate court reviews de novo whether a question falls within the booking-question exception to Miranda, and routine booking questions that are reasonably related to administrative processing do not constitute custodial interrogation.

Connick v. Thompson

563 U.S. 51 (2011) · Mar 29, 2011

A district attorney's office may not be held liable under § 1983 for failure to train prosecutors based on a single Brady violation — absent a pattern of similar violations, a single incident is generally insufficient to prove deliberate indifference.

Erickson v. Pardus

551 U.S. 89 (2007) · Jun 4, 2007

Rule 8(a)(2) requires only a short and plain statement of the claim, not specific facts, and a pro se complaint must be liberally construed and held to less stringent standards than a pleading drafted by a lawyer.

Palo ex rel. Estate of Palo v. Dallas County

No. 3:05-CV-0527-D (N.D. Tex. 2006) · Dec 15, 2006

A pretrial detainee's estate could proceed to trial on a Fourteenth Amendment conditions-of-confinement claim where the county jail failed to provide adequate medical care to a detainee with serious medical conditions, resulting in his death.

United States v. Lugo

289 F. Supp. 2d 790 (S.D. Tex. 2003) · Oct 17, 2003

Denied motion to suppress statements made by a defendant who was questioned as part of the BORCAP program at a county jail, finding that Miranda warnings were properly administered and that the defendant's waiver of his right to counsel was knowing and voluntary.

Hope v. Pelzer

536 U.S. 730 (2002) · Jun 27, 2002

A constitutional right can be 'clearly established' for qualified immunity purposes even without a prior case involving identical facts — the obvious cruelty of the conduct itself can provide fair warning.

Atwater v. City of Lago Vista

532 U.S. 318 (2001) · Apr 24, 2001

The Fourth Amendment does not forbid a warrantless custodial arrest for a minor criminal offense — even a misdemeanor punishable only by a fine — as long as the officer has probable cause.

Texas DPS v. Petta

44 S.W.3d 575 (Tex. 2001) · Mar 29, 2001

Collateral estoppel barred a plaintiff's civil assault claims against a trooper where a criminal jury had already found beyond a reasonable doubt that the plaintiff did not reasonably believe she faced imminent harm from the trooper's actions; the Texas Department of Public Safety was entitled to sovereign immunity because the claims arose out of intentional torts excluded from the Tort Claims Act's waiver.

Mendenhall v. Riser

213 F.3d 226 (5th Cir. 2000) · May 30, 2000

Officers who had arguable probable cause to arrest a suspect for murder were entitled to qualified immunity, even though the suspect was later exonerated at a preliminary hearing when another person confessed.

Smith v. Brenoettsy

No. 97-30587 (5th Cir. 1998) · Nov 5, 1998

An interlocutory appeal from denial of qualified immunity to a prison warden on a failure-to-supervise claim was dismissed for lack of jurisdiction because the warden raised only factual disputes—not separable legal issues—regarding whether he acted with deliberate indifference after receiving letters warning him of a guard's threats.

County of Sacramento v. Lewis

523 U.S. 833 (1998) · May 26, 1998

A police officer does not violate substantive due process by causing death through deliberate or reckless indifference to life in a high-speed automobile chase aimed at apprehending a suspected offender; only a purpose to cause harm unrelated to legitimate law enforcement objectives violates the Fourteenth Amendment in such circumstances.

Thompson v. City of Galveston

No. G-97-171 (S.D. Tex. 1997) · Dec 12, 1997

Claims of false arrest, false imprisonment, and malicious prosecution on behalf of a mother who pled nolo contendere were barred by Heck v. Humphrey; claims on behalf of a minor who confessed to murders under alleged coercion were dismissed for failure to state a claim where confession was later contradicted by another suspect's admission.

Spiller v. City of Texas City Police Department

130 F.3d 162 (5th Cir. 1997) · Dec 1, 1997

Probable cause exists when the totality of facts and circumstances within a police officer's knowledge at the moment of arrest are sufficient for a reasonable person to conclude that the suspect had committed or was committing an offense; officers who arrested a suspect based on eyewitness identification and surrounding circumstances had probable cause.

Siglar v. Hightower

112 F.3d 191 (5th Cir. 1997) · May 8, 1997

A prisoner's bruised and sore ear lasting three days constituted a de minimis injury insufficient to support an Eighth Amendment excessive force claim or to meet the physical injury requirement of the Prison Litigation Reform Act for mental or emotional suffering claims.

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).

Heck v. Humphrey

512 U.S. 477 (1994) · Jun 24, 1994

A § 1983 claim for damages is barred if success on that claim would necessarily imply the invalidity of an existing criminal conviction — the conviction must first be reversed or invalidated.

Salas v. Carpenter

980 F.2d 299 (5th Cir. 1992) · Dec 16, 1992

A sheriff who commanded police efforts to free a hostage was entitled to qualified immunity where the hostage was killed by her abductor, because the plaintiff failed to state a claim for deprivation of constitutional rights arising from the failed rescue operation.

Townsend v. State

813 S.W.2d 181 (Tex. App.—Houston [14th Dist.] 1991) · Jun 27, 1991

Affirmed DWI conviction, holding that the trial court did not abuse its discretion in finding the defendant's consent to a breath test was voluntary, and that an officer's observation of weaving between lanes provided reasonable suspicion for a traffic stop.

Pfannstiel v. City of Marion

918 F.2d 1178 (5th Cir. 1990) · Dec 12, 1990

Officers were not entitled to qualified immunity where genuine issues of material fact existed regarding whether they used excessive force and conducted unlawful searches during a confrontation with citizens in Marion, Texas.

Will v. Michigan Department of State Police

491 U.S. 58 (1989) · Jun 15, 1989

Neither a state nor its officials acting in their official capacity are 'persons' under § 1983 — meaning § 1983 cannot be used to sue states or state officials in their official capacity for money damages.

Graham v. Connor

490 U.S. 386 (1989) · May 15, 1989

All claims that law enforcement officers used excessive force during an arrest, investigatory stop, or other seizure of a free citizen must be analyzed under the Fourth Amendment's 'objective reasonableness' standard — not substantive due process.

Gladden v. Roach

864 F.2d 1196 (5th Cir. 1989) · Jan 17, 1989

Routine booking questions seeking biographical information (name, address, date of birth) do not constitute interrogation under the Fifth Amendment and Miranda, so an arrestee has no constitutional right to refuse to answer them; however, detention for 87 hours before arraignment violated the arrestee's rights.

Jackson v. Procunier

789 F.2d 307 (5th Cir. 1986) · May 9, 1986

A prisoner stated a First Amendment and due process claim where prison officials deliberately interfered with his legal mail, causing him to miss a court deadline, thus depriving him of his right to access the courts.

Thomas v. Arn

474 U.S. 140 (1985) · Dec 4, 1985

A court of appeals may adopt a rule that a party who fails to file timely objections to a magistrate judge's report and recommendation forfeits appellate review of the unobjected findings, so long as the party was warned of that consequence.

Raley v. Fraser

747 F.2d 287 (5th Cir. 1984) · Nov 26, 1984

Where an officer used four choke holds and caused bruises and scrapes during an arrest for public intoxication, the force constituted assault and battery under state law but did not rise to the level of a Section 1983 excessive force violation under then-existing precedent requiring severe injuries.

Baker v. McCollan

443 U.S. 137 (1979) · Jun 26, 1979

Detention pursuant to a facially valid arrest warrant does not violate the Fourteenth Amendment's Due Process Clause merely because the wrong person was arrested, and a sheriff executing a valid warrant is not constitutionally required to independently investigate every claim of innocence.

Stone v. Powell

428 U.S. 465 (1976) · Jul 6, 1976

Where a state has provided an opportunity for full and fair litigation of a Fourth Amendment claim, a state prisoner may not obtain federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search or seizure was introduced at trial.

Pierson v. Ray

386 U.S. 547 (1967) · Apr 11, 1967

Police officers sued under § 1983 may raise the defense of good faith and probable cause — the origin of what would later become qualified immunity.