Batiste Ex Rel. Pierre v. Theriot, 458 F. App'x 351

Batiste and family sued St. Martin Parish Sheriff and deputies under 42 U.S.C. § 1983 for death following a police chase and taser of Othello Pierre.
Claims included excessive force, failure to provide medical care, wrongful death, and failure to train; state-law wrongful death claims were also asserted.
District court granted the Sheriff qualified immunity in his individual capacity but denied immunity for the deputies; other claims proceeded.
Pierre fled after being informed of an outstanding felony arrest warrant; Lasher, Johnson pursued and tased him as he tried to flee.
Autopsy attributed death to multi-drug intoxication; plaintiffs’ experts suggested sickling from exertion, while EMS and timing facts showed rapid ambulance response and treatment limitations.
Court reverses, granting qualified immunity to officers and granting judgment as a matter of law on remaining claims, then remands for further proceedings on retroactive effects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether taser use and pursuit amounted to excessive force	Batiste argues taser caused death; use of force was unlawful.	Pierre was a fleeing suspect; taser use was reasonable under the circumstances.	Qualified immunity for officers affirmed; tasing not deadly force; excessive force claim rejected.
Whether officers denied medical care with deliberate indifference	Defendants delayed or failed to provide medical care to Pierre.	Care provided promptly; no deliberate indifference shown.	District court erred; officers entitled to qualified immunity; no constitutional violation shown.
Whether wrongful death claim under §1983 survives	Death resulted from officers’ unconstitutional acts or omissions.	No unconstitutional act or causation shown; lawful pursuit and taser use.	Wrongful death claim dismissed on appeal; no proximate cause shown.
Whether Sheriff Theriot can be liable in official capacity for failure-to-train	Policy or pattern of training failures caused unconstitutional outcomes.	No demonstrated pattern or deliberate indifference; training followed policy.	Official-capacity claims against Sheriff reversed; no failure-to-train liability found.
Whether state-law negligence claims can be adjudicated on pendent basis	State-law claims should proceed alongside federal claims.	Different standards; no basis for pendent jurisdiction.	Court exercises pendent appellate jurisdiction and resolves state-law claims in line with federal rulings.

Tennessee v. Garner, 471 U.S. 1 (Supreme Court) (deadly force standard for fleeing felons; context for use-of-force analysis)
Fontenot v. Cormier, 56 F.3d 669 (5th Cir. 1995) (elements of excessive force standard)
Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (medical-needs and deliberate indifference framework)
Mace v. City of Palestine, 333 F.3d 621 (5th Cir. 2003) (subjective knowledge requirement for medical indifference)
Oklahoma City v. Tuttle, 471 U.S. 808 (Supreme Court) (single-incident training failure not sufficient for §1983 failure-to-train)
Connick v. Thompson, 563 U.S. 51 (Supreme Court) (policy-level liability requires a pattern or practice showing deliberate indifference)