Pratt v. Harris County, TX, No. 15-20080 (5th Cir. 2016)
Annotate this CasePlaintiff, the mother of Wayne Pratt, filed suit under 42 U.S.C. 1983, alleging that officers of the HCSD caused her son's death by using excessive force in restraining him during his arrest. Plaintiff also alleged a claim under Monell v. New York City Dept. of Social Services, that the County was also liable for Wayne's death. The district court granted qualified immunity to HCSD officers in their individual capacities and denied the Monell claim. The court concluded that plaintiff has not shown that Deputies Lopez and Medina's use of tasers was clearly excessive or unreasonable. Therefore, the court held that the district court did not err in granting qualified immunity to these deputies. In light of Wayne's “on again, off again” commitment to cease resisting, his recurring violence, and the threat he posed while unrestrained, it was not, under the totality of the circumstances, clearly excessive or unreasonable for HCSD officers to restrain him by hog-tying him. Therefore, the court held that the district court did not err in granting Deputies Wilks, Goldstein, and Salazar qualified immunity. Because there is no Fourth Amendment violation, the court affirmed the judgment in all respects.
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