Henderson v. Harris County

Summary

The Fifth Circuit affirmed dismissal of Monell claims against Harris County for failure to state a claim, holding that the plaintiff’s conclusory allegations of no training or policies on taser use did not plausibly show deliberate indifference, especially where the officer received TCOLE training and the single-incident exception did not apply. The court also affirmed summary judgment for the officer based on qualified immunity, finding that no clearly established law—including Newman v. Guedry and Darden v. City of Fort Worth—squarely governed the facts of a fleeing suspect who stopped and turned suddenly, and that the obvious-case exception did not apply. The case addresses Fourth Amendment excessive force, municipal liability under § 1983, failure-to-train, and the specificity required to overcome qualified immunity in taser incidents involving flight.

Holdings

1. The district court properly dismissed the Monell claim because Henderson failed to plausibly allege that the County failed to train, that there was a causal connection, or that the failure constituted deliberate indifference.
2. The district court properly granted summary judgment because Henderson failed to show that the law was clearly established that using a taser under these circumstances was unconstitutional, and the obvious-case exception did not apply.
3. The district court did not abuse its discretion because Henderson had ample time to seek leave to amend and the court's factual characterization did not alter the outcome.

Questions Presented

1. Whether the district court erred in dismissing the Monell claim against Harris County for failure to state a claim.
2. Whether the district court erred in granting summary judgment to Officer Garduno based on qualified immunity.
3. Whether the district court abused its discretion in denying Henderson's Rule 59(e) motion.

Disposition

affirmed