Michelle Skyy v. City of Arlington
712 F. App'x 396
5th Cir.2017Background
- Skyy and Valdez separated; a domestic dispute led Skyy to call Arlington police after Valdez grabbed her and retrieved an AR-15.
- APD officers arrived, took Skyy to a park, arrested Valdez, then entered the couple’s home without a warrant or consent and searched it; a warrant for the rifle arrived later.
- Officers also entered Skyy’s vehicle without her consent and had it towed; Skyy was subsequently arrested and taken to Arlington jail.
- At booking Skyy reported medical conditions and dietary needs but allegedly received no food for ~48 hours and was held in a small cell without water or restroom for over six hours, causing physical suffering.
- Appellants sued the City under 42 U.S.C. § 1983 for Fourth and Eighth Amendment violations and sought punitive damages; they relied on provisions of the City Personnel Manual to allege municipal liability.
- The district court dismissed the Complaint for failure to plead a Monell policy or custom and rejected punitive damages as barred by City of Newport; the Fifth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability under § 1983 (Monell) | City is liable because its Personnel Manual sets rules officers must follow and those rules were violated here | City cannot be held vicariously liable; plaintiffs must plead a municipal policy or custom causing the constitutional injury | Dismissed: plaintiffs pleaded only an isolated incident and policy language; no facts showing a policy, custom, or deliberate indifference sufficient for Monell liability |
| Existence of a municipal custom or deliberate indifference | Reliance on Manual and officers’ failure to follow it shows City-wide policy or ratification | Single-incident allegations do not establish a persistent, widespread practice or deliberate indifference | Dismissed: single incident and cited Manual provisions insufficient to allege custom or deliberate indifference |
| Sufficiency of pleading by pro se plaintiffs | Pro se complaints should be liberally construed; factual allegations suffice to raise claim above speculative level | Standard for pleading remains applicable; must allege facts linking policy/custom to injury | Court applied liberal construction but still found pleading deficient under Rule 12(b)(6) |
| Punitive damages against municipality | Plaintiffs sought $5,000,000 punitive damages for constitutional violations | Punitive damages against municipalities are barred absent clear congressional authorization | Denied: punitive damages against the City are barred by City of Newport |
Key Cases Cited
- Monell v. Department of Social Services of City of New York, 436 U.S. 658 (establishes municipal liability framework under § 1983)
- City of Newport v. Fact Concerts, Inc., 453 U.S. 247 (municipalities immune from punitive damages absent congressional authorization)
- City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train requires deliberate indifference)
- Piotrowski v. City of Houston, 237 F.3d 567 (isolated violations do not establish municipal custom)
- Peterson v. City of Fort Worth, 588 F.3d 838 (definition and proof of municipal custom)
- James v. Harris County, 577 F.3d 612 (municipal liability requires policy or custom as moving force)
- Gil Ramirez Group v. Houston Indep. Sch. Dist., 786 F.3d 400 (application of City of Newport to bar punitive damages against municipalities)