Cuadra v. Houston Independent School District
626 F.3d 808
| 5th Cir. | 2010Background
- Cuadra worked as a network specialist at SHS and had access to SASI, PEIMS, and TEA data uploads.
- Cuadra and Martin edited leaver codes; Cuadra alone could upload drop-out data to PEIMS, which fed TEA.
- On Oct 22–23, 2002 Cuadra allegedly deleted ten to fifteen names to influence a meeting.
- Cuadra allegedly later restored data; Martin allegedly changed drop-out data back to zero.
- Hardin outside counsel conducted an investigation confirming Cuadra knowingly changed leaver codes without authorization.
- Cuadra was indicted for false alteration of a governmental record; district court granted summary judgment to Appellees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Cuadra has a freestanding Fourth Amendment malicious-prosecution claim | Cuadra asserts a direct Fourth Amendment violation. | Castellano forecloses freestanding malicious-prosecution claims under §1983. | No freestanding malicious-prosecution claim. |
| Whether Cuadra raised genuine Fourth Amendment issues besides malicious prosecution | Cuadra alleges false arrest/unreasonable seizure and lack of probable cause. | Independent intermediaries broke chain of causation; probable cause supported by Cuadra's admitted changes. | No genuine Fourth Amendment violation; no probable-cause issue. |
| Whether Cuadra's Fourteenth Amendment substantive due process claim survives | Cuadra claims pretrial deprivation of rights without probable cause. | Albright requires Fourth Amendment analysis; substantive due process not available here. | Fourteenth Amendment claim foreclosed; analyzed under Fourth Amendment. |
Key Cases Cited
- Castellano v. Fragozo, 352 F.3d 939 (5th Cir. en banc 2003) (no freestanding malicious-prosecution under §1983)
- Albright v. Oliver, 510 U.S. 266 (Supreme Court 1994) (prosecution without probable cause analyzed under Fourth Amendment)
- Napue v. Illinois, 360 U.S. 264 (Supreme Court 1959) (false evidence taints conviction; not applicable here)
- Taylor v. Gregg, 36 F.3d 453 (5th Cir. 1994) (taint must be shown to affect intermediary decisions; no evidence here)
- Glenn v. City of Tyler, 242 F.3d 307 (5th Cir. 2001) (unreasonable seizure requires more than alleged hurt; none shown)