Sweetin v. City of Texas City, 48 F.4th 387

Wendell Wylie, a fire-captain serving as Texas City’s designated "permit officer"/EMS Administrator, monitored compliance with the City’s non-emergency ambulance-permit rules.
Wylie observed a Windsor ambulance operating without a permit, photographed it, and followed the vehicle while he called the Fire Marshal (who had authority to cite).
After the ambulance completed a patient transfer, Wylie told the drivers they were "detained" and could not leave while they waited (about 30 minutes) for the Fire Marshal to arrive and issue citations.
The drivers (Sweetin and Stefek) sued Wylie (individually) and the City under 42 U.S.C. § 1983, alleging an unreasonable seizure in violation of the Fourth Amendment.
The district court granted summary judgment for Wylie and the City, concluding qualified immunity applied and that Wylie lacked final policymaking authority.
The Fifth Circuit held Wylie was not entitled to qualified immunity because he acted outside his discretionary authority by detaining the drivers, but affirmed that the City was not liable because Wylie did not have final policymaking authority; the case was remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wylie is entitled to qualified immunity for detaining the ambulance drivers	Wylie unlawfully seized them in violation of the Fourth Amendment; his conduct was not within his discretionary authority so no immunity	Wylie acted within his discretionary role as permit officer/EMS supervisor and his conduct could reasonably be believed lawful	Court: Wylie did not act within his discretionary authority (state law gives no power to effect stops); qualified immunity denied
Whether the City is liable under § 1983 via Wylie’s actions (Monell)	Wylie had final policymaking authority (or was delegated such authority), so a single act can impose municipal liability	Wylie lacked final policymaking authority; his regulatory authority was subject to City Commission approval	Court: Wylie lacked final policymaking authority; City not liable under § 1983

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires an official policy or custom)
Morgan v. Swanson, 659 F.3d 359 (5th Cir. 2011) (en banc) (qualified-immunity standard explained)
Cherry Knoll, L.L.C. v. Jones, 922 F.3d 309 (5th Cir. 2019) (scope of an official’s discretionary authority is determined by state law)
Bevill v. Fletcher, 26 F.4th 270 (5th Cir. 2022) (qualified-immunity two-step restatement)
Webb v. Town of Saint Joseph, 925 F.3d 209 (5th Cir. 2019) (single-act municipal liability requires final policymaker status)
Valle v. City of Houston, 613 F.3d 536 (5th Cir. 2010) (discretion to perform a function does not automatically confer final policymaking authority)
Zarnow v. City of Wichita Falls, 614 F.3d 161 (5th Cir. 2010) (definition of final policymaker: sets goals and decides means for a city function)
Robinson v. Hunt County, 921 F.3d 440 (5th Cir. 2019) (final policymaker standard under state law)
Bennett v. City of Slidell, 728 F.2d 762 (5th Cir. 1984) (policymaker acts in place of governing body and is not supervised on the substance of decisions)
Powell v. City of Houston, 628 S.W.3d 838 (Tex. 2021) (home-rule cities’ powers and charter interpretation)