Cormier v. Lafayette City-Parish Consolidated Government
493 F. App'x 578
5th Cir.2012Background
- Cormier, a retired Lafayette police officer, owned property in Lafayette and called police to report trespassing; Martin and Guidry responded.
- During investigation, Greer and Cormier were involved in an altercation; Cormier allegedly admitted to possessing a pistol after Sergeant Sheridan arrived.
- Martin issued a misdemeanor summons for simple battery against Cormier and released him; later a statement, summons, and witness statements were given to Deputy City Marshal Picard.
- Prosecutor Haynes filed charges; media coverage followed, affecting Cormier’s City Marshall election bid; charges evolved and he was ultimately convicted of disturbing the peace.
- Cormier filed federal and state-law claims against Lafayette, Haynes, Mouton, Stelly, Martin, Guidry, and others; district court granted some summary judgments and denied others.
- The Fifth Circuit reversed in part, holding Heck v. Humphrey precludes §1983 claims against Stelly and Martin and defeats related state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Heck bar §1983 claims against Stelly and Martin individually? | Cormier argues the §1983 claims survive independent of the criminal judgment. | Stelly and Martin contend Heck bars any§1983 claims challenging the validity of the conviction. | Yes; Heck bars the §1983 claims against Stelly and Martin. |
| Do Cormier's state-law claims against the officers and Lafayette fail as a matter of law? | Cormier seeks false arrest, malicious prosecution, and defamation against officers and Lafayette. | Defendants contend the conviction and probable cause defeat these state-law claims and no actionable conduct by Haynes supported liability. | Yes; state-law claims fail due to conviction and lack of actionable conduct. |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (bar §1983 claims that would undermine criminal judgment)
- Connors v. Graves, 538 F.3d 373 (5th Cir. 2008) (false arrest/malicious-prosecution concerns implicate Heck)
- Wells v. Bonner, 45 F.3d 90 (5th Cir. 1995) (malicious prosecution and false arrest tied to probable cause)
- Devenpeck v. Alford, 543 U.S. 146 (U.S. 2004) (probable-cause inquiry not limited to offense invoked)
- Paul v. Davis, 424 U.S. 693 (U.S. 1976) (stigmainfringement/defamation with privacy considerations)
- Roche v. Aetna Cas. & Sur. Co., 303 So. 2d 888 (La. Ct. App. 1st Cir. 1974) (defamation merged into prosecutorial actions when underlying claim not actionable)