Langiano v. City of Fort Worth
131 F.4th 285
5th Cir.2025Background
- Tracy Langiano was accused of sexually abusing his step-granddaughters and was believed to be suicidal, armed, and a risk to himself and possibly others.
- Langiano’s son alerted authorities about Langiano’s mental state and his possession of a handgun; police tracked Langiano to a motel room.
- Police entered the motel room without a warrant, and Officer Landon Rollins shot Langiano when encountering him holding a gun; Langiano survived and was not criminally charged.
- Langiano filed a civil § 1983 suit against Officer Rollins and the City of Fort Worth, claiming excessive force and municipal liability; during discovery, Langiano invoked his Fifth Amendment rights while the related criminal case was pending.
- The district court denied Langiano’s motion to stay the civil case, granted summary judgment for the defendants, and dismissed the action.
- Langiano appealed the denial of the stay and the grant of summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of Motion to Stay Pending Criminal Case | Stay was needed to avoid prejudice while criminal charges pending | No substantial or irreparable prejudice to plaintiff; delay harms others | Denial affirmed; no abuse of discretion |
| Qualified Immunity – Excessive Force | Use of force was excessive and unreasonable | Officer reasonably perceived a deadly threat from armed Langiano | Officer entitled to qualified immunity |
| Warrantless Entry – Exigent Circumstances | Entry without warrant violated Fourth Amendment | Entry was reasonable due to imminent threat of suicide | Warrantless entry justified by exigent circumstances |
| Municipal Liability under § 1983 (Monell claim) | City failed to train, causing rights violations | No constitutional violation by city employee; no policy at issue | No Monell liability since no constitutional violation |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity protects acts not violating clearly established rights)
- Graham v. Connor, 490 U.S. 386 (standard for objective reasonableness in use of force)
- Monell v. Dep't of Soc. Servs., 436 U.S. 658 (municipal liability under § 1983 requires a policy causing violation)
- Brigham City v. Stuart, 547 U.S. 398 (exceptions to warrant requirement for exigent circumstances)