Hutcheson v. Dallas County, No. 20-10383 (5th Cir. 2021)
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After Joseph Hutcheson died as a result of police officers restraining him at the Dallas County Jail, Hutcheson's wife and mother filed suit against the county and four individual officers, bringing an excessive force claim against the officers and failure-to-train and wrongful-death claims against the county. Hutcheson died from a combination of the narcotics in his system and the stress from his struggle with and restraint by the officers. The district court dismissed or granted summary judgment on all claims.
The Fifth Circuit affirmed the district court's grant of summary judgment on the excessive force claim, concluding that plaintiffs failed to raise a dispute of material fact regarding whether the officers used unreasonable force to restrain a resisting suspect. The court also concluded that the district court did not abuse its discretion by denying the motion for limited discovery on the issue of qualified immunity. The court further concluded that the district court properly dismissed the failure-to-train claim where plaintiffs failed to allege that the county provided no training, so they cannot show that the county was deliberately indifferent. Finally, the court concluded that the district court did not abuse its discretion in denying leave to file a second amendment. Accordingly, the court affirmed the district court's judgment in its entirety.
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