Michelle Martinez v. Maverick County
507 F. App'x 446
5th Cir.2013Background
- Martinez was stopped for misdemeanor offenses in Eagle Pass, Texas.
- She resisted arrest and attempted to flee in her vehicle at high speed.
- Deputies pursued and used tactics, including steering the vehicle off the road and shooting tires.
- Deputies fired 15–18 shots at Martinez’s vehicle, striking her in the neck and causing quadriplegia.
- The district court granted summary judgment for defendants on §1983 and state claims; this court affirmed for substantially the same reasons.
- Martinez and her family challenged the district court’s rulings on denial of medical care, Sheriff’s Office policy or custom, inadequate training, individual deputies’ qualified immunity, and official immunity under Texas law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of medical care claim viability | Martinez alleges improper or delayed medical care | No additional harm beyond initial injury shown | Claim failed as a matter of law |
| Policy or custom of the Sheriff’s Office | Wide-ranging corruption implies an unconstitutional policy | No specific injury-causing policy identified | Insufficient to support municipal liability |
| Inadequate training claim | Training was constitutionally deficient | County training complied with state mandates; no pattern of violations shown | No triable issue; summary judgment affirmed |
| Individual deputies’ qualified immunity | Use of force was excessive or unreasonable | Use of force reasonable given threat; qualified immunity applies | Qualified immunity upheld; no constitutional violation shown |
| Official immunity and Texas immunity waiver | Deputies and Sheriff liable under Texas immunity rules | Officials entitled to official immunity; county immune under Texas Tort Claims Act | Official immunity and county immunity confirmed; no waiver for state claims |
Key Cases Cited
- Mendoza v. Lynaugh, 989 F.2d 191 (5th Cir. 1985) (denial of medical care standard for ongoing harm must be shown)
- Piotrowski v. City of Houston, 237 F.3d 567 (5th Cir. 2001) (unconstitutional policy or custom requires injury-causing policy and causal link)
- Brown v. Board of County Commissioners, 520 U.S. 397 (U.S. 1997) (supervisory liability requires direct causal link, not mere respondeat superior)
- Burge v. St. Tammany Parish, 336 F.3d 363 (5th Cir. 2003) (pattern of violations required to prove failure-to-train claim)
- Ontiveros v. City of Rosenberg, 564 F.3d 379 (5th Cir. 2009) (deadly force presumptively reasonable when threat present)