Shaw v. Villanueva, No. 17-50937 (5th Cir. 2019)Annotate this Case
Plaintiff filed suit alleging that the county sheriff and others had conspired to violate his civil rights in an action arising from the political feud in Karnes County stemming from the Eagle Ford Shale oil boom. The Fifth Circuit reversed the district court's denial of qualified immunity to the county sheriff and the deputy sheriff.
The court applied the independent-intermediary doctrine and held that the district court erred in denying qualified immunity to the county sheriff and deputy sheriff given plaintiff's bare-bones allegations that defendants arrested him purely because of their political feud with plaintiff's wife. The court held that plaintiff's 42 U.S.C. 1985 claim failed because he failed to allege facts sufficient to show an actual deprivation of his rights. Furthermore, plaintiff's conspiracy to violate 42 U.S.C. 1983 claim failed because plaintiff only asserted legal allegations, unsupported by sufficient factual content, that was insufficient to state a plausible claim for relief.