Clayton v. Garland Police Department
3:09-cv-02048
N.D. Tex.Jun 1, 2011Background
- Clayton sues Garland Police Department and several officers; only Worsham, Hatfield, and Vancleave remain as defendants after dismissals.
- Arrest warrant for Clayton issued Oct 28, 2007, based on his statements and investigation; he was arrested at 10:00 p.m. and booked on murder charges with $500,000 bond.
- Clayton was held on a parole warrant and later transferred to Dallas County Sheriff’s Office after charges were dismissed; he then filed §1983 and state-law claims.
- Defendants move for summary judgment on qualified immunity; Clayton did not respond.
- Court finds undisputed facts show probable cause and good faith; grants summary judgment for the defendants on §1983 and state-law claims, with dismissal in favor of Worsham, Hatfield, and Vancleave.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants are entitled to qualified immunity for Clayton’s §1983 false-arrest claim | Clayton contends arrest lacked probable cause | Defendants argue there was probable cause and good faith | Yes, qualified immunity applies; no constitutional violation established. |
| Whether probable cause supported the arrest warrant | Clayton argues lack of probable cause given lies and inconsistencies | Officers relied on totality of circumstances and affidavit evidence | Yes, probable cause existed based on totality of facts at time of arrest. |
| Whether official immunity bars Clayton’s state-law false-arrest claims | Clayton asserts state claims despite immunity | Defendants maintain good-faith, discretionary acts within authority | Yes, official immunity applies; state-law claims barred. |
Key Cases Cited
- White v. Taylor, 959 F.2d 539 (5th Cir. 1992) (qualified immunity framework; clearly established rights)
- Malley v. Briggs, 475 U.S. 335 (1986) (deadly standard for assessing good faith; unreasonable mistakes)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-prong inquiry for qualified immunity)
- Pearson v. Callahan, 555 U.S. 223 (2009) (modifies order of prongs in qualified-immunity analysis)
- Brinegar v. United States, 338 U.S. 160 (1949) (probable cause standard in arrest decisions)
- United States v. Preston, 608 F.2d 626 (5th Cir. 1979) (probable cause requires reasonable belief based on facts)
- Franks v. Delaware, 438 U.S. 154 (1978) (affidavit presumption of validity in warrants)
- United States v. Levine, 80 F.3d 129 (5th Cir. 1996) (totality-of-circumstances approach to probable cause)
- Ventresca, 380 U.S. 102 (1965) (common-sense, realistic testing of warrants)
- James v. Brown, 637 S.W.2d 914 (Tex. 1982) (Texas official-immunity standards)
- Wal-Mart Stores, Inc. v. Resendez, 962 S.W.2d 539 (Tex. 1998) (official-immunity standards for false-arrest claims)