Melancon v. Walsh
24-30232
| 5th Cir. | Feb 7, 2025Background
- Chad Melancon, a contractor, was arrested for residential contractor fraud after a homeowner alleged he did incomplete work and demanded more money.
- Officer Bradley Walsh applied for Melancon’s arrest warrant based on an affidavit summarizing the homeowner's complaints and observations of purported unfinished or substandard work.
- Walsh did not include certain information in the affidavit, such as Melancon’s position that he was owed more money, or Walsh’s lack of precise knowledge of monetary discrepancies.
- Melancon was arrested on December 30, 2022, and was held in jail until he posted bond on January 4, 2023; the district attorney later refused to prosecute the charges.
- Melancon sued Walsh and Sheriff Champagne, asserting federal constitutional claims (false arrest, malicious prosecution, Monell liability) and state law claims, seeking monetary damages.
- The district court dismissed all claims, finding probable cause supported the warrant and qualified immunity shielded defendants; Melancon appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable Cause for Arrest | Walsh omitted material facts negating probable cause (Franks violation). | Warrant supported by probable cause; omissions not material. | No Franks violation; probable cause existed. |
| False Arrest Claim | Arrest unlawful due to missing/exculpatory facts in affidavit. | Facial validity of warrant bars false arrest claim. | Dismissed; probable cause defeats the claim. |
| Malicious Prosecution | No probable cause; prosecution pursued in bad faith. | Lack of Franks violation and probable cause bar claim. | Dismissed; no constitutional violation pled. |
| Monell/Official Liability | Municipal liability for unconstitutional policy or lack of training. | No underlying constitutional violation supports Monell claim. | Dismissed; no federal right deprivation shown. |
Key Cases Cited
- Franks v. Delaware, 438 U.S. 154 (officer violates Fourth Amendment by knowingly/recklessly providing false information in warrant affidavit)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausible claim under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (must plead enough facts to state a facially plausible claim)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability arises only for action under official policy causing deprivation of rights)
- District of Columbia v. Wesby, 583 U.S. 48 (probable cause analysis considers totality of circumstances)