Taylor v. LeBlanc, 21-30625

Percy Taylor was originally sentenced in 1995 to 10 years, later paroled; he committed a new felony (2001), was arrested in 2002, convicted in 2003, and ultimately received a 20‑year sentence (after a habitual offender designation) with credit for time served.
Taylor alleged his good‑time/credit calculations were wrong and that pretrial custody (Feb 20, 2002–Oct 15, 2003) should have been credited to both the 1995 and 2003 sentences, producing an earlier release date.
Taylor pursued the prison Administrative Remedy Procedure; the warden and Secretary James LeBlanc denied relief under then‑applicable state law prohibiting overlapping credits for consecutive sentences.
A state court commissioner recommended recalculation of Taylor’s master prison record to credit the overlapping custody; the state district court adopted that recommendation.
Taylor was released Feb 18, 2020, then sued under 42 U.S.C. § 1983 for false imprisonment, asserting supervisory liability against Secretary LeBlanc for failing to implement policies/training to prevent overdetention.
The district court denied qualified immunity as to the supervisory claim; the Fifth Circuit reversed because Taylor forfeited any meaningful argument that LeBlanc’s conduct was objectively unreasonable in light of clearly established law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether LeBlanc is entitled to qualified immunity on the supervisory §1983 claim for overdetention	LeBlanc failed to enact policies/training and was aware of a pattern of overdetentions, so he’s liable	LeBlanc argues his conduct wasn’t objectively unreasonable given the law and facts; qualified immunity applies	Reversed district court denial of qualified immunity because plaintiff forfeited the objective‑unreasonableness argument
Whether the right to timely release was clearly established	Taylor: inmates have a clearly established right to timely release	LeBlanc: contested reasonableness of his actions, not that the right exists	The right is clearly established (court acknowledges prior Fifth Circuit precedent)
Whether objective unreasonableness is a factual question precluding interlocutory review	Taylor: it’s a fact issue not suitable for appellate resolution now	LeBlanc: it’s a legal question suitable for interlocutory review	Court: objective‑reasonableness is a purely legal question; appellate review proper
Whether Taylor adequately briefed objective unreasonableness	Taylor: Secretary’s failure to enact policies is inherently unreasonable	LeBlanc: Taylor failed to meaningfully brief the issue; forfeiture applies	Court: Taylor’s single conclusory sentence forfeits the argument; plaintiff bears burden to rebut qualified immunity

Porter v. Epps, 659 F.3d 440 (5th Cir. 2011) (jailer duty to ensure timely inmate release)
Douthit v. Jones, 619 F.3d 527 (5th Cir. 2010) (detention past sentence absent valid order is due‑process deprivation)
Crittindon v. LeBlanc, 37 F.4th 177 (5th Cir. 2022) (holding month‑long overdetention denies due process; documenting systemic DPSC overdetentions)
Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (qualified immunity framework; courts may choose prong order)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (clearly established standard: unlawfulness must be apparent; fair‑warning principle)
Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (clarifying ‘‘would it be clear to a reasonable official’’ test for clearly established rights)
Kinney v. Weaver, 367 F.3d 337 (5th Cir. 2004) (objective‑reasonableness is a legal question reviewable on interlocutory appeal)
Hare v. City of Corinth, Miss., 135 F.3d 320 (5th Cir. 1998) (distinguishing objective‑reasonableness from deliberate indifference)