Opinion

Singh v. City of Greenville, MS

Court
Court of Appeals for the Fifth Circuit
Filed
Jan 16, 2026
Status
Unpublished
Nature of suit
Civil Rights
Cited by
0 cases
Authority
More cited than 38.2%

The opinion

Case: 24-60644 Document: 54-1 Page: 1 Date Filed: 01/16/2026

United States Court of Appeals

for the Fifth Circuit United States Court of Appeals

Fifth Circuit

____________

FILED

January 16, 2026

No. 24-60644

____________ Lyle W. Cayce

Clerk

Surjit Singh; Santokh Singh; Satvinder Kaur,

Plaintiffs—Appellants,

versus

The City of Greenville, Mississippi; Martavis Moore,

Police Officer for City of Greenville, Mississippi; Carl Nichols, Chief Fire

Marshal for City of Greenville, Mississippi,

Defendants—Appellees.

______________________________

Appeal from the United States District Court

for the Northern District of Mississippi

USDC No. 4:22-CV-195

______________________________

Before Jones, Duncan, and Douglas, Circuit Judges.

Per Curiam: *

We have reviewed the briefs, district court opinion, and pertinent

portions of the record and find no reversible error.

One of the plaintiff-appellants’ contentions merits further discussion.

The Singhs make much of the fact that the district court referenced Villareal

_____________________

*

This opinion is not designated for publication. See 5th Cir. R. 47.5.

Case: 24-60644 Document: 54-1 Page: 2 Date Filed: 01/16/2026

No. 24-60644

v. City of Laredo, 94 F.4th 374, 398 (5th Cir. 2024) (en banc), cert. granted,

judgment vacated, and remanded, Villareal v. Alaniz, 145 S. Ct. 368 (2024),

which the Supreme Court has since vacated. Regardless of the Supreme

Court’s decision, the district court reached the correct result. The Supreme

Court in Villareal remanded to this court with instructions to reconsider the

case in the light of Gonzalez v. Trevino, 602 U.S. 653, 658, 144 S. Ct. 1663,

1667 (2024). Gonzalez determined that where, as here, plaintiffs must

present comparator evidence about the treatment of similarly situated

people, they need not show examples of people in “virtually identical”

circumstances who received different treatment. Gonzalez, 602 U.S. at 658,

144 S. Ct. at 1667. But while Gonzalez lowered the bar for the type of

comparator evidence plaintiffs must present, it did not eliminate the

requirement altogether. Because the Singhs do not point to any evidence of

unequal treatment, they fail to satisfy even the less stringent standard

established by Villareal and Gonzalez. 1 The district court’s conclusion that

the Singhs’ claim fails because they “ha[ve] not provided one example of

another individual who was treated differently than them” remains valid in

the wake of the Supreme Court’s decision.

Moreover, even if the district court reached the incorrect conclusion

about the strength of the plaintiffs’ comparator evidence, qualified immunity

_____________________

1

Nor is their argument that the city targeted them alone sufficient to show unequal

treatment, because the record does not adequately support the Singhs’ contention. The

video evidence of the City’s spraying only captures the portion of the road in front of the

Singhs’ property, so it reveals nothing about whether further spraying happened at other

properties on the road. Furthermore, that the property adjacent to theirs suffered no visible

damage from herbicides does not foreclose the possibility that it or other properties were

sprayed. Thus, the Singhs have failed to demonstrate that they were singled out or targeted

with herbicide spraying.

2

Case: 24-60644 Document: 54-1 Page: 3 Date Filed: 01/16/2026

No. 24-60644

shields the individual defendants and the absence of a pattern or practice

giving rise to a violation prevents municipal liability.

Finding no reversible error, we AFFIRM.

3

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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