Marion Taite, Jr. v. City of Fort Worth, Texas
681 F. App'x 307
5th Cir.2017Background
- On July 6, 2010, Taite was arrested by Fort Worth officers and later alleged an officer searched his unlocked car without a warrant while he was jailed.
- Taite sued the City of Fort Worth under 42 U.S.C. § 1983 alleging a warrantless vehicle search and municipal liability.
- Taite amended to add individual officers (Scott, McLaughlin, Gray); the district court later dismissed those officers for failure to plead facts showing they searched the car.
- The City moved for summary judgment (2015), arguing Taite produced no evidence of a constitutional violation or a municipal policy causing one; the district court granted summary judgment for the City.
- Taite also moved to compel discovery after the City initially failed to respond (an admitted oversight); the court extended deadlines, the City later produced responses, and the court denied Taite’s subsequent motion to compel as unwarranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether underlying constitutional violation (warrantless search) occurred | Taite: officers searched his car without a warrant | City: Taite produced no evidence of any search or illegality | No; Taite neither pled nor proved a constitutional violation — summary judgment affirmed |
| Whether City liable under Monell for alleged search | Taite: City’s policy/practice caused deprivation | City: No underlying violation, so no municipal liability | No municipal liability because no underlying constitutional violation |
| Whether district court abused discretion by denying motion to compel (second motion) | Taite: City’s discovery responses were deficient; sought interrogatories directed to former officers | City: Responded to available, non-objectionable requests; not required to answer for former defendants represented separately | No abuse of discretion; court correctly found City’s responses adequate and refusal to answer interrogatories for non-defendants proper |
| Whether discovery oversight warranted default judgment | Taite: sought default or compelling relief for initial failure to respond | City: oversight was unintentional, agreed to produce, and requested extensions | Denial of default judgment affirmed; court granted extensions and City produced responses |
Key Cases Cited
- Haase v. Countrywide Home Loans, Inc., 748 F.3d 624 (5th Cir.) (summary-judgment standard on appeal)
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (U.S.) (municipal liability requires a policy/practice causing constitutional violation)
- Kitchen v. Dallas County, Tex., 759 F.3d 468 (5th Cir.) (Monell requires an underlying constitutional violation)
- Outley v. Luke & Associates, Inc., 840 F.3d 212 (5th Cir.) (discovery rulings reviewed for abuse of discretion)
- McCreary v. Richardson, 738 F.3d 651 (5th Cir.) (same - standard for reviewing discovery rulings)