Laymance v. Shourd, 4:17-cv-00303

Background

In Feb–Mar 2017 the child’s great-grandparents (the Van Compernolles) petitioned a Texas court for sole managing conservatorship and obtained a temporary restraining order (TRO) restricting Laymance from removing the child.
Sharon Van Compernolle reported to Texas authorities that Laymance had taken the child; Texas issued an Amber Alert and alerted White County, Arkansas law enforcement.
On March 2, 2017 White County deputies stopped and handcuffed Laymance, held him for several hours while awaiting confirmation of a Texas warrant, and paramedics turned the child over to Arkansas DHS worker Casey Walker.
On March 3, 2017 the Texas court proceeded in absentia, awarded temporary (then later permanent) sole managing conservatorship to the Van Compernolles, and a Texas arrest warrant for interference with child custody was signed; Laymance was arrested in Arkansas pursuant to that warrant.
Laymance sued Walker, Sheriff Ricky Shourd, Deputy Paul Hofstead, and the counties under 42 U.S.C. § 1983 alleging unlawful arrest and unlawful removal of the child; defendants moved for judgment on the pleadings asserting Rooker–Feldman, res judicata, qualified immunity, and other defenses.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdictional bar by Rooker–Feldman	Laymance contends his §1983 claims challenge unlawful conduct (arrests and removal) not the Texas judgment.	Defendants argue the claims seek review of state-court custody determinations and are barred.	Court: Rooker–Feldman does not apply because the alleged injuries (March 2–3 arrests and March 2 removal) preceded the state-court judgment.
Qualified immunity for March 2 warrantless detention	Laymance says Hofstead unlawfully detained/arrested him on March 2 without probable cause.	Defendants say Amber Alert and sighting of the child in Laymance’s car gave at least arguable probable cause/ reasonable basis for an investigative stop and temporary detention.	Court: No constitutional violation; March 2 conduct was objectively reasonable and officers entitled to qualified immunity.
Qualified immunity for March 3 arrest under Texas warrant	Laymance claims the March 3 arrest pursuant to a Texas warrant was unlawful.	Defendants note the arrest was executed on a facially valid warrant; arresting officers not liable absent knowledge warrant was illegal.	Court: Arrest under a facially valid warrant does not give rise to §1983 liability; no allegation officers knew arrest was illegal; qualified immunity applies.
Removal of child by DHS worker (Walker)	Laymance contends Walker unlawfully took the child on March 2 without a court order or notice of the TRO.	Walker argues she acted pursuant to enforcement following Amber Alert and TRO; her conduct was not clearly unconstitutional.	Court: No clearly established law warned Walker her conduct was unconstitutional under these facts; Walker entitled to qualified immunity.
Official‑capacity and municipal liability	Laymance alleges county liability based on policies/practices causing violations.	Defendants argue Eleventh Amendment bar (state actors) and lack of any underlying constitutional violation to attribute to the counties.	Court: Official‑capacity claim against Walker barred by Eleventh Amendment; Anderson and White County claims dismissed because no constitutional violation shown.

Key Cases Cited

Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Rooker–Feldman limited to federal review of state-court judgments)
Arbaugh v. Y & H Corp., 546 U.S. 500 (jurisdictional issues and sequencing)
Saucier v. Katz, 533 U.S. 194 (qualified immunity two‑step analysis)
Pearson v. Callahan, 555 U.S. 223 (discretion to decide qualified immunity prongs)
Stanton v. Sims, 571 U.S. 3 (qualified immunity protects reasonable but mistaken judgments)
United States v. Hensley, 469 U.S. 221 (BOLO/alert can justify investigative stop)
District of Columbia v. Wesby, 138 S. Ct. 577 (probable cause standard is low; requires only a probability of criminal activity)
United States v. Leon, 468 U.S. 897 (warrant reliance limits liability)
Fair v. Fulbright, 844 F.2d 567 (arrest under facially valid warrant generally shields arresting officer from §1983 liability)
Ehlers v. City of Rapid City, 846 F.3d 1002 (arguable probable cause and objective reasonableness in wrongful‑arrest claims)