Opinion

Howard v. City Of Houston

Court
District Court, S.D. Texas
Filed
Apr 18, 2022
Cited by
0 cases
Authority
More cited than 31.9%

“It is well established that ‘municipalities have no immunity from damages liability flowing from their constitutional violations.’” (quoting Owen v. City of Independence, 445 U.S. 622, 657, 100 S. Ct. 1398 (1980))

How later courts described this case

  • “It is well established that ‘municipalities have no immunity from damages liability flowing from their constitutional violations.’” (quoting Owen v. City of Independence, 445 U.S. 622, 657, 100 S. Ct. 1398 (1980))
  • accepting an amended complaint wrongfully alters the status of an interlocutory appeal
  • while the city manager pursued an interlocutory appeal of the denial of qualified immunity, the district court permitted discovery to proceed for the claims against the City of Balch Springs—including discovery requests of the city manager

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT April 19, 2022

SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk

HOUSTON DIVISION

AUNDRE HOWARD, §

§

Plaintiff, §

§

v. § CIVIL ACTION H-21-1179

§

CITY OF HOUSTON, TEXAS, et al., §

§

Defendants. §

MEMORANDUM OPINION AND ORDER

Pending before the court is the City of Houston (the “City”) and Art Acevedo’s

(collectively, the “City Defendants”) motion to stay all proceedings pending a determination of

Acevedo’s interlocutory appeal. Dkt. 68. Having considered the motion, response, replies, and

the applicable law, the court is of the opinion that the motion should be DENIED.

I. BACKGROUND

This case arises out of alleged police misconduct during a traffic stop. See Dkt. 28.

Plaintiff Aundre Howard brought claims against four Houston police officers and the City

Defendants. Id. The court discussed the allegations in detail previously and will not repeat them

here. See Dkt. 57 at 1–4. The City Defendants and three police officers—Thomas Serrano,

Nadeem Aslam, and Earl Attebury—filed separate motions to dismiss for failure to state a claim.

Dkts. 31, 32, 33, 34, 42. In their motions, Acevedo and the three officers invoked qualified

immunity. Dkts. 31, 32, 33, 42.

The court’s February 16, 2022, order denied qualified immunity for Acevedo on Howard’s

excessive force claim. Dkt. 57 at 17–22. While the court dismissed multiple claims, claims remain

against the City Defendants and Serrano. Id. at 30–31. A fourth officer, Lucas Vieira,

subsequently filed a motion to dismiss that is still pending. Dkt. 60. On March 16, 2022, Acevedo

filed a notice of interlocutory appeal on the denial of qualified immunity. Dkt. 66. The next day,

the City Defendants filed the instant motion to stay all proceedings pending the resolution of that

appeal. Dkt. 68.

II. LEGAL STANDARD

The power to stay a case is an inherent power of the court to control its docket with

“economy of time and effort for itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299

U.S. 248, 254, 57 S. Ct. 163 (1936). It comes from the court’s “authority to control the scope and

pace of discovery.” In re Ramu Corp., 903 F.2d 312, 318 (5th Cir. 1990). Analysis of a motion

to stay involves weighing competing interests and maintaining an even balance. Wedgeworth v.

Fibreboard Corp., 706 F.2d 541, 545 (5th Cir. 1983) (quoting Landis, 299 U.S. at 254–55). The

moving party bears the burden of justifying a delay. Id.

III. ANALYSIS

Acevedo’s notice of interlocutory appeal “confers jurisdiction on the court of appeals and

divests the district court of its control over those aspects of the case involved in the appeal.”

Wooten v. Roach, 964 F.3d 395, 403 (5th Cir. 2020) (quoting Griggs v. Provident Consumer Disc.

Co., 459 U.S. 56, 58, 103 S. Ct. 400 (1982)). Thus, the court “does not have the power to ‘alter

the status of the case as it rests before the Court of Appeals.’” Dayton Indep. Sch. Dist. v. U.S.

Min. Prods. Co., 906 F.2d 1059, 1063 (5th Cir. 1990) (quoting Coastal Corp. v. Tex. E. Corp., 869

F.2d 817, 820–21 (5th Cir. 1989)).

The City Defendants request that the court go further and stay all proceedings, including

aspects of the case not involved in the appeal. See Dkt. 68. As the movants, the City Defendants

have the burden of justifying the delay caused by such a stay. See Wedgeworth, 706 F.2d at 545.

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To this end, the City Defendants put forth two arguments in favor of a stay.1 See Dkt. 68. First,

the City Defendants claim that Acevedo’s qualified immunity would “effectively be lost” absent a

stay. Id. ¶ 10. Second, the City Defendants argue that because the claims against the City and

Acevedo involve identical facts, discovery requests relating to those facts would improperly alter

the status of the appellate proceedings. Id. ¶¶ 11–12. The court rejects both arguments.

Acevedo has the right to immediately appeal the court’s denial of qualified immunity

“[b]ecause immunity is ‘effectively lost if a case is erroneously permitted to go to trial.’” Backe

v. LeBlanc, 691 F.3d 645, 648 (5th Cir. 2012) (quoting Mitchell v. Forsyth, 472 U.S. 511, 526–27,

105 S. Ct. 2805 (1985)). “One of the most salient benefits of qualified immunity is protection

from pretrial discovery, which is costly, time-consuming, and intrusive.” Id. (citing Helton v.

Clements, 787 F.2d 1016, 1017 (5th Cir. 1986)).

From this, the City Defendants argue that unless all proceedings are stayed, Acevedo will

effectively lose qualified immunity because he will be “required to engage in discovery, defend

the allegations against him, and participate in pretrial and trial of this matter.” Dkt. 68 ¶ 10.

However, the City Defendants have not explained how allowing discovery to proceed for the

claims against the City, Serrano, and Vieira—which are not on appeal—would cost Acevedo

anything. See Dkts. 68, 73. Therefore, at best, the court concludes that this argument potentially

justifies only a stay of proceedings for claims against Acevedo, but the City Defendants’ second

argument undercuts that more limited position.

1 In their reply, the City Defendants also make the dubious argument that Howard’s response

to the instant motion was so insufficient that the court ought to deem he waived any opposition to

the proposed stay. See Dkt. 73 ¶ 3. Howard’s response, while minimal, clearly opposes the instant

motion and asserts legal arguments with citations to binding and persuasive authority. See Dkt. 72.

The court concludes that the instant motion is properly opposed and will rule on the merits.

3

Howard’s claims against the City rely on the same alleged facts as those supporting his

claim against Acevedo. Dkt. 68 ¶ 12. The City Defendants’ second argument is that since both

sets of claims involve the same facts, then Acevedo’s appeal necessarily impacts the claims against

the City, and the court should stay the case pending that appeal. Id. This argument fails because

the City is a municipality and does not enjoy qualified immunity. See Trent v. Wade, 776 F.3d

368, 388 (5th Cir. 2015) (“It is well established that ‘municipalities have no immunity from

damages liability flowing from their constitutional violations.’” (quoting Owen v. City of

Independence, 445 U.S. 622, 657, 100 S. Ct. 1398 (1980))). The sole issue on appeal is the court’s

order denying qualified immunity to Acevedo. See Dkt. 66. The court’s order was on a Rule

12(b)(6) posture. Dkts. 33, 57. In considering a Rule 12(b)(6) motion, the court generally must

accept the factual allegations contained in the complaint as true. Kaiser Aluminum & Chem. Sales,

Inc. v. Avondale Shipyards, Inc., 677 F.2d 1045, 1050 (5th Cir. 1982). Thus, the limited scope of

the appeal—whether Acevedo is entitled to qualified immunity under the facts alleged in the

complaint—has no impact on the claims against the City, and subsequent discovery will not alter

an analysis of the complaint.

Further, the mutual implication of the same alleged facts between claims against the City

Defendants supports denying a stay in the instant case. Qualified immunity “is a right to immunity

from certain claims, not from litigation in general.” Behrens v. Pelletier, 516 U.S. 299, 312, 116

S. Ct. 834 (1996) (emphasis original). To the extent that a defendant is subject to discovery for

claims for which he cannot assert qualified immunity, an interlocutory appeal on qualified

immunity does not impact such discovery requests. Alice L. v. Dusek, 492 F.3d 563, 565 (5th Cir.

2007). Thus, even if Acevedo obtains qualified immunity on appeal, he would still be required to

4

subject himself to the same discovery requests because the facts involved would be relevant to the

claims against the City.

Instead of showing justification for the delay caused by a stay, the City Defendants’

arguments only clarify that proceeding with discovery and other pretrial matters would be the most

efficient and just course of action in this situation. A motion that would alter the status of the

appeal must be stayed for lack of jurisdiction. See, e.g., Wooten, 964 F.3d at 404 (accepting an

amended complaint wrongfully alters the status of an interlocutory appeal). However, courts often

allow discovery to proceed for claims against other defendants while one defendant pursues an

interlocutory appeal for denial of qualified immunity. See, e.g., Harris v. City of Balch Springs,

33 F. Supp. 3d 730, 733 (N.D. Tex. 2014) (while the city manager pursued an interlocutory appeal

of the denial of qualified immunity, the district court permitted discovery to proceed for the claims

against the City of Balch Springs—including discovery requests of the city manager). By the City

Defendants’ own admission, any discovery requests for Acevedo will relate to the claims against

the City. Dkt. 68 ¶ 12. Thus, even if Acevedo obtains qualified immunity on appeal, he will be

subject to the same discovery requests, and there is no need to cause unnecessary delay. See Dusek,

492 F.3d at 565.

Finally, defendants Serrano and Vieira filed a reply brief in support of the City Defendants’

motion, arguing that a stay is proper because neither officer is currently subject to any discovery.

Dkt. 76 ¶ 5. Serrano and Vieira overstate the scope of any potential qualified immunity. See

Pelletier, 516 U.S. at 312. Serrano was denied qualified immunity for allegedly conducting an

unreasonable strip search. Dkt. 57 at 23–28. Serrano did not appeal, and discovery is proper

concerning that claim. Vieira’s claim of qualified immunity is still pending before the court.

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Dkt. 60. However, like Acevedo, both officers are properly subject to discovery requests for the

claims against the City. See Dusek, 492 F.3d at 565.

IV. CONCLUSION

For the reasons provided above, the court concludes that it would be most efficient to

proceed with discovery and other pretrial proceedings that do not alter the status of Acevedo’s

appeal. Additionally, the defendants have failed to justify further delay. Therefore, the City

Defendants’ motion to stay (Dkt. 68) is DENIED.

Signed at Houston, Texas on April 18, 2022.

Seniok United States\District Judge

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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