Espinal v. City of Houston, No. 23-20075 (5th Cir. 2024)
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Maximo Espinal, a security guard, was arrested by Houston police officers for aggravated assault. Although a grand jury initially indicted Espinal, the charges were subsequently dropped. Espinal then sued the officers involved and the City of Houston, claiming he had been subjected to false arrest, malicious prosecution, and assault. The district court dismissed all of Espinal's claims based on the officers' qualified immunity and immunity under Texas law.
Espinal's arrest occurred after he had a heated interaction with a plainclothes police officer, M.T. Long, who was trespassing on the property Espinal was guarding. After Espinal instructed Officer Long to leave, the officer returned with multiple police vehicles and arrested Espinal. Espinal alleged that the officers made no effort to view or collect video surveillance evidence that he said would prove his innocence.
The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court ruled that the officers had probable cause for Espinal's arrest. Furthermore, the court found that even if the officers had lacked probable cause, the grand jury's subsequent indictment of Espinal shielded them from liability under the independent intermediary doctrine. The court also rejected Espinal's claim that he had been maliciously prosecuted, finding that Espinal failed to allege that the officers had misled the grand jury. Finally, the court ruled that Espinal's assault claim was barred by the Texas Tort Claims Act.
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