Joe Anthony Alaniz v. Harris County, et al.

Summary

The United States District Court for the Southern District of Texas ruled on summary-judgment motions arising from Joe Anthony Alaniz’s arrest during a 2020 George Floyd protest in Houston. The court granted Harris County’s motion, granted Deputy Mark Cannon’s motion as to the false-arrest claim, and denied it as to the excessive-force claim because disputed facts precluded qualified-immunity judgment at the summary-judgment stage.

Holdings

1. Summary judgment was inappropriate on the excessive-force claim because disputed issues of material fact existed concerning the reasonableness and proportionality of Cannon's use of force. Cannon was not entitled to qualified immunity at the summary-judgment stage.
2. Cannon was entitled to qualified immunity and summary judgment on the false-arrest claim because Alaniz's admission that he pulled away from Cannon while Cannon attempted to handcuff him supplied at least arguable probable cause to believe Alaniz was resisting arrest.
3. Harris County was entitled to summary judgment on Alaniz's Monell policy-or-practice theories because he failed to establish an official policy or persistent custom, policymaker knowledge, and causation.
4. Harris County was entitled to summary judgment on the failure-to-train claim because Alaniz did not identify an inadequate training program, deliberate indifference, or causation.
5. Harris County was entitled to summary judgment on the ratification claim because failure to discipline or mere acquiescence did not establish policymaker approval of the subordinate's decision and the case was not an extreme factual situation.

Questions Presented

1. Whether Deputy Cannon was entitled to qualified immunity and summary judgment on Alaniz's § 1983 excessive-force claim.
2. Whether Deputy Cannon was entitled to qualified immunity and summary judgment on Alaniz's § 1983 false-arrest claim.
3. Whether Harris County was entitled to summary judgment on Monell claims based on an unconstitutional policy or practice, failure to train, and ratification.

Disposition

other