Jennings v. Patton
2011 U.S. App. LEXIS 12381
| 5th Cir. | 2011Background
- Jennings sued Judge Patton under 42 U.S.C. § 1983 claiming he was prosecuted without probable cause.
- Judge Patton moved to dismiss or for summary judgment, asserting judicial and qualified immunity.
- District court denied summary judgment due to genuine issues of material fact surrounding misrepresentation claims.
- Jennings alleged Patton misrepresented settlement negotiations to the DA, contributing to arrest and indictment.
- An investigator’s affidavit and grand jury testimony supported indictments for bribery of a judge, which were later remanded
- The court of appeals held Patton entitled to qualified immunity, reversing the district court's denial of summary judgment
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly denied qualified immunity | Jennings argues genuine facts show a violation | Patton argues immunity shields him from §1983 claims | Qualified immunity applies; district court reversal |
| Whether misrepresentation tainted the arrest warrant and indictment | Misrepresentations caused probable cause issues | Intermediary independence breaks causation | No §1983 violation shown due to independent intermediary doctrine applicability |
| Whether the intermediary (magistrate/grand jury) breaks the causal chain | Defendant tainted deliberations, affecting warrant/indictment | Intermediary independent, untainted by Patton's actions | Intermediary chain not tainted; immunity applies |
| Whether the right at issue was clearly established | Right to be free from prosecution without probable cause was violated | No clearly established right shown given intermediaries | Right not clearly established in this context; qualified immunity affirmed |
| Whether the court has jurisdiction to review the availability of qualified immunity | Appeal should challenge factual genuineness | Review limited to legal questions; factual disputes reviewed for materiality | Court has jurisdiction to review materiality; de novo on materiality |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (2009) (two-step qualified immunity analysis)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-pronged test for qualified immunity)
- Castellano v. Fragozo, 352 F.3d 939 (5th Cir. 2003) (initiation of charges without probable cause may violate rights; intermediary actions may trigger §1983)
- Cuadra v. Houston Indep. Sch. Dist., 626 F.3d 808 (5th Cir. 2010) (independent intermediary doctrine; chain of causation may remain)
- Michalik v. Hermann, 422 F.3d 252 (5th Cir. 2005) (liability not extended to those who did not prepare warrant)
- Hampton v. Oktibbeha Cnty Sheriff Dept., 480 F.3d 358 (5th Cir. 2007) (affirmative immunities where defendants not the affiant or warrant preparer)
- Kinney v. Weaver, 367 F.3d 337 (5th Cir. 2004) (jurisdiction to review factual disputes limited to materiality)