Latiolais v. Cravins, 574 F. App'x 429

Latiolais sued Griffith, Cravins, Officer Gallow, and the City in 2009 alleging §1983 and Louisiana tort claims arising from a custody dispute over Cole.
Cravins, a former Louisiana state senator, admitted conversations with Griffith and a $1,000 campaign contribution; he also admitted making a call to Deputy Montgomery during the custody investigation.
Deputy Montgomery testified Cravins asked him to “help [Griffith] out,” which Montgomery later characterized as anger at Griffith’s case, not Cravins’ official conduct.
Griffith and Latiolais settled before trial; the trial proceeded against Griffith, Officer Gallow’s estate (surviving spouse Claudette Gallow), and the City of Opelousas.
The district court granted Cravins’ JMOL and dismissed him from the case; the jury found liability against Griffith and Gallow, with damages awarded on state-law claims and nothing for §1983 claims.
The Fifth Circuit vacated the judgment, reversed on the settlement-content ruling, and remanded for a new trial with reassignment to a different district judge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the JMOL against Cravins was proper	Latiolais contends Cravins’ involvement supported conspiratorial liability.	Cravins argues the evidence fails to show a conspiracy or intent.	JMOL against Cravins reversed; trial to be conducted anew.
Whether the district court erred by admitting content of the Griffith–Latiolais settlement	Settlement content is protected by Rule 408 and must be excluded.	Content was permissible to limit jury confusion as to absent co-defendant.	District court abused discretion; exclude settlement content on remand.
Whether reassignment to a new district judge is warranted on remand	Reassignment is necessary to preserve the appearance of justice.	No bias established; reassignment not necessary.	Reassignment required; case to be assigned to a different judge.

Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Supreme Court 2000) (standard for evaluating a JMOL via reasonable inferences)
X Techs., Inc. v. Marvin Test Sys., Inc., 719 F.3d 406 (5th Cir. 2013) (evidentiary standards on review and related issues)
Boeing Co. v. Shipman, 411 F.2d 365 (5th Cir. 1969) (en banc approach to bias and reassignment principles)
Bryant v. Compass Grp. USA Inc., 413 F.3d 471 (5th Cir. 2005) (guidance on Rule 408 and settlement evidence considerations)
Branch v. Fid. & Cas. Co. of N.Y., 783 F.2d 1289 (5th Cir. 1986) (bias and appearance of fairness considerations in reassignment)