Wooten v. Roach

Summary

The court considers motions to dismiss claims brought by Suzanne H. Wooten against Collin County prosecutors, Texas Attorney General defendants, and Collin County arising from her investigation, prosecution, and convictions following a judicial election. The opinion analyzes prosecutorial immunity, qualified immunity, official immunity under Texas law, and potential county liability under 42 U.S.C. § 1983. The court denies the Collin County District Attorney defendants' motion, grants the County's motion in part and denies it in part, and denies the Attorney General defendants' motion, while allowing Wooten an opportunity to replead in connection with qualified immunity.

Holdings

1. The CCDAO defendants were not entitled to dismissal based on absolute prosecutorial immunity because the complaint plausibly alleged that they investigated Wooten to develop probable cause and find a crime, rather than acting as advocates preparing an existing case for judicial proceedings.
2. At the pleading stage, some of White's alleged conduct was plausibly investigative and not absolutely immune, while his later conduct involving appointment to the Attorney Pro Team, presenting evidence to obtain an indictment, conveying a dismissal offer, and withholding exculpatory evidence was protected prosecutorial conduct.
3. The AG defendants were not entitled to dismissal based on Texas official immunity because the complaint alleged that they acted maliciously, making it inappropriate to conclusively establish good faith at the motion-to-dismiss stage.
4. Wooten plausibly alleged that Collin County had an official policy of pursuing arrests and prosecutions without probable cause and due process, and that the Collin County District Attorney could act as a county policymaker for that policy.
5. Wooten's claims were not barred by the two-year statute of limitations because the claims were part of an alleged malicious-prosecution conspiracy and accrued when her conviction was favorably terminated through habeas relief on May 24, 2017.
6. Collin County was immune from punitive damages under 42 U.S.C. § 1983, so the County's motion was granted on that issue.
7. The court granted Wooten leave to file an amended complaint because amendment was not shown to be futile and additional factual detail would assist in resolving qualified-immunity and constitutional-claim issues.

Questions Presented

1. Whether the alleged investigative and prosecutorial conduct of the CCDAO defendants and AG defendants was protected by absolute prosecutorial immunity at the pleading stage.
2. Whether the AG defendants established official immunity under Texas law at the motion-to-dismiss stage.
3. Whether Wooten plausibly alleged that Collin County had an official policy, practice, or custom causing the alleged constitutional violations.
4. Whether Wooten's claims were barred by the applicable two-year statute of limitations.
5. Whether Collin County could be liable for punitive damages under 42 U.S.C. § 1983.
6. Whether Wooten should be permitted to amend her complaint to clarify her constitutional and supervisory-liability allegations.

Disposition

other