# Opinion

> District Court, N.D. Texas · August 27, 2026

URL: https://www.frixlaw.com/law-library/cases/11428752

## Case

- **Full name:** Peter Williams, et al. v. Dallas-Fort Worth International Airport Board, et al.
- **Court:** District Court, N.D. Texas
- **Decided:** August 27, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

PETER WILLIAMS, ET AL.,

Plaintiffs,

v. No. 4:26-cv-00433-P

DALLAS-FORT WORTH INTERNATIONAL
AIRPORT BOARD, ET AL.,

Defendants.

MEMORANDUM OPINION & ORDER

Before the Court is Defendant’s Motion to Dismiss. ECF No. 10.
Having reviewed the filing and the relevant law, the Court will GRANT
Defendants’ Motion to Dismiss as to the Section 1983 claims and
declines to exercise supplemental jurisdiction over the remaining
claims.
BACKGROUND
On April 14, 2024, Plaintiffs Peter Williams and Dr. Mary Jane
Williams were ticketed passengers on American Airlines flights from
Evansville, Indiana to Phoenix, Arizona with a connection at Dallas-
Fort Worth International Airport (“DFW”). ECF No. 2 at 5. During a
dispute over baggage policy between Plaintiffs and American Airlines,
Defendant Officer B. Jackson and three unidentified officers responded
to the jetway. ECF No. 2 at 5. After some back and forth, officers and
airline personnel eventually instructed Mr. Williams to vacate the
jetway. ECF No. 2 at 6. Mr. Williams nevertheless attempted to re-board
the aircraft, at which point Officer Jackson grabbed Mr. Williams. ECF
No. 2 at 6. Plaintiffs and Defendant dispute what happens next.
Compare ECF No. 2 at 6 with ECF No. 10 at 9.
According to police body-cam footage, Officer Jackson stated that Mr.
Williams was “under arrest now” and attempted to restrain him. ECF
No. 18-1, Exhibit 4 at 2:06. Mr. Williams can be heard replying “No”
repeatedly and appears to be physically resisting arrest for a period of
roughly 25 seconds. ECF No. 18-1, Exhibit 4 at 2:10–2:45. Eventually,
Officer Jackson takes Mr. Williams to the ground in what appears to be
an attempt to restrain and handcuff him. ECF No. 18-1, Exhibit 4 at
2:45–2:51. Mr. Williams continues to writhe on the ground, evading
handcuffs, at which point Officer Jackson places knee in his back and
once again informs him that he is under arrest. ECF No. 18-1, Exhibit 4
at 2:52. Once more, Mr. Williams replies repeatedly “No.” ECF No. 18-
1, Exhibit 4 at 2:53–2:55. There is then a period of brief respite wherein
Officer Jackson continues to have his knee on Mr. Williams who is
audibly objecting but does not appear to be actively resisting, though his
hands remain uncuffed. ECF No. 18-1, Exhibit 4 at 3:00–3:15. After this
period, Officer Jackson informs Mr. Williams that “if you do not put your
hands behind your back, you will be tased.” ECF No. 18-1, Exhibit 4 at
3:15. Mr. Williams nevertheless continues to verbally object and
physically resists Officer Jackson’s attempt to restrain his hands. ECF
No. 18-1, Exhibit 4 at 3:26. Officer Jackson finally discharges his taser
once to Mr. Williams’ side. ECF No. 18-1, Exhibit 4 at 3:29.
Plaintiffs filed suit against the Dallas-Fort Worth International
Airport Board (“the Board”), Dallas-Fort Worth Airport Department of
Public Safety, Officer Jackson, and bystander officers on April 8th, 2026,
alleging civil-rights violations under 42 U.S.C § 1983 and advancing
various state-law claims. ECF No. 1. On June 22nd, 2026, Defendant
offered the Motion now under consideration.
LEGAL STANDARDS
Under Fed R. Civ. P. 12(b)(6), dismissal is appropriate if Plaintiffs’
pleading fails to state a claim upon which relief can be granted. In
conducting that review, the Court accepts “all well-pleaded facts as true
and draw[s] all reasonable inferences in favor of the nonmoving party.”
Morgan v. Swanson, 659 F. 3d 359, 370 (5th Cir. 2011) (en banc). The
court does not, however, “presume true a number of categories of
statements, including legal conclusions; mere labels; threadbare recitals
of the elements of a cause of action; conclusory statements; and naked
assertions devoid of further factual enhancement.” Id. (cleaned up)
(quoting Ashcroft v. Iqbal., 556 U.S. 662, 678, 129 S. Ct. 1937, 1949
(2009)).
A court ruling on a motion to dismiss “may rely on the complaint, its
proper attachments, documents incorporated into the complaint by
reference, and matters of which a court may take judicial notice.”
Randall D. Wolcott M.D., P.A. v. Sebelius, 635 F.3d 757, 763 (5th Cir.
2011). Further, a court may permissibly consider “[d]ocuments that a
defendant attaches to a motion to dismiss” without converting the
motion to dismiss to a motion for summary judgment if those documents
“are referred to in the plaintiff's complaint and are central to her
claim.”1 Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 499 (2000)
(quoting Venture Assocs. Corp. v. Zenith Data Sys. Corp., 987 F.2d 429,
431 (7th Cir. 1993)). Moreover, where video recordings are included in
the pleadings, the video depictions of events, viewed in the light most
favorable to the plaintiffs, should be adopted over the factual allegations
in the complaint if the video “blatantly contradict[s]” those allegations.
Scott v. Harris, 550 U.S. 372, 380, 127 S. Ct. 1769, 1776 (2007).
ANALYSIS
The Court’s analysis proceeds in three parts. First, the Court reasons
that Plaintiffs’ Section 1983 claims against Officer Jackson are barred
by qualified immunity and should therefore be dismissed. This applies
with equal force to Plaintiffs’ claims as to bystander liability. Second,
the Court finds that the Plaintiffs have not plausibly alleged a claim for
municipal liability. Third, the Court concludes that it may, in its
discretion, decline to hear Plaintiffs’ remaining state law claims.
A. The Officers are Entitled to Qualified Immunity Because
No Clearly Established Law “Squarely Governs”
“Qualified immunity protects officers from suit unless their conduct
violates a clearly established [statutory or] constitutional right.”

1 This applies, too, to video exhibits. See Esco v. City of Chicago, 107 F.4th 673, 678
(7th Cir. 2024) (writing that “the court, therefore, may examine exhibits, including
video exhibits, attached to the complaint, or referenced in the pleading if they are
central to the claim”); Johnson v. City of Atlanta, 107 F.4th 1292, 1298 (11th Cir. 2024)
(affirming the district court’s consideration of video evidence despite it not being
attached to, or even mentioned in, the plaintiff’s complaint).
Converse v. City of Kemah, 961 F.3d 771, 774 (5th Cir. 2020) (quoting
Mace v. City of Palestine, 333 F.3d 621, 623 (5th Cir. 2003)). “Although
qualified immunity is nominally an affirmative defense, the plaintiff
bears a heightened burden to negate the defense once properly raised.”
Newman v. Guedry, 703 F.3d 757, 761 (5th Cir. 2012) (citation omitted).
Plaintiff bears the burden to “plead facts which, if proved, would defeat
the claim of immunity.” Waller v. Hanlon, 922 F.3d 590, 599 (5th Cir.
2019) (citation omitted).
Accordingly, Officer Jackson is entitled to qualified immunity at the
motion-to-dismiss stage unless Plaintiffs have alleged facts sufficient to
plausibly show that (1) the defendant’s conduct violated a constitutional
right and (2) the constitutional right was clearly established at the time
of the alleged misconduct. Pearson v. Callahan, 555 U.S. 223, 232, 129
S. Ct. 808, 816 (2009). The Court has discretion as to which of the two
prongs should be analyzed first. Cope v. Cogdill, 3 F.4th 198, 236 (2021).
Because Plaintiffs do not carry their burden as to the clearly established
prong, this Court need not evaluate the validity of the excessive force
claim.
Plaintiffs do not plausibly show that Officer Jackson violated any
“clearly established” right. This burden is a heavy one: A right is “clearly
established” only if preexisting precedent “ha[s] placed the . . .
constitutional question beyond debate.” Ashcroft v. al-Kidd, 563 U.S.
731, 741 (2011). This restrictive analysis provides that the right must
be “sufficiently clear that every reasonable official would have
understood that what he is doing violates that right.” Mullenix v. Luna,
577 U.S. 7, 11 (2015) (per curiam) (internal quotation marks and citation
omitted). Courts must not "define clearly established law at a high level
of generality"; instead, their "inquiry must be undertaken in light of the
specific context of the case." Id. at 12 (internal quotation marks and
citations omitted). Therefore, unless existing precedent "squarely
governs" the conduct at issue, an official will be entitled to qualified
immunity. See Brosseau v. Haugen, 543 U.S. 194, 201 (2004) (per
curiam); Mullenix, 577 U.S. at 12 (emphasizing that "[t]he dispositive
question is whether the violative nature of particular conduct is clearly
established" (internal quotation marks and citation omitted)).
To put it pointedly, Plaintiffs must "identify[] a case in which an
officer acting under similar circumstances was held to have violated the
[Constitution], and . . . explain[] why the case clearly proscribed the
conduct of that individual officer." Joseph ex rel. Estate of Joseph v.
Bartlett, 981 F.3d 319, 345 (5th Cir. 2020). This cannot be undertaken
at too broad a level of generality, id., and it certainly cannot be
established by citation to nonexistent cases.2
Here, Plaintiffs make a borderline sanctionable attempt to identify
“clearly established” law from five cases. ECF No. 18. Three of these
cases—Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997), Yates v. Terry, 817
F.3d 877 (4th Cir. 2016), and Dawkins v. Fields 354 F.3d 392 (5th Cir.
2003)—are either non-existent or mistakenly out-of-circuit and, in any
event, inapposite. With respect to Dawkins, this Court cannot even find
a case purporting to “clearly establish” law on the matter and wastes its
limited judicial resources in doing so. As to Iko, mistakenly cited as a
5th Circuit case, Plaintiffs presumably meant to refer to Iko v. Shreve,
535 F.3d 225 (4th Cir. 2008). But this out-of-circuit case concerned
correctional officers who broke up a fight by administering pepper spray
to a non-confrontational inmate, not a taser applied to a resistant
passenger. It therefore cannot constitute “clearly established” law in
this Circuit nor “squarely governs” on its own facts. The same is true of
Yates. This out-of-circuit decision concerned an officer who tased a non-
resisting arrestee three separate times. Id. at 881. There, the officer
tased Yates for a second time when the suspect was already on the
ground “ma[king] no attempt to get up” and a third time after he asked
his brother to call for the officer’s supervisor. Id. Yates is thus both non-

2 The Court cautions that use of generative artificial intelligence that results in
repeated misrepresentations of law may qualify for sanctions under Fed. R. Civ. P.
11(b)–(c) (“The rule . . . require[s] litigants to ‘stop-and-think’ before initially making
legal or factual contentions . . . A litigant’s obligations . . . include reaffirming to the
court and advocating positions contained in those pleadings and motions after learning
that they cease to have any merit.”); Tex. Disciplinary Rules Prof’l Conduct R. 3.01 (“A
lawyer shall not . . . assert or controvert an issue [in a proceeding], unless the lawyer
reasonably believes that there is a basis for doing so that is not frivolous.”); Id.
3.03(a)(1) (“A lawyer shall not knowingly . . . make a false statement of material fact
or law to a tribunal”); Id. 8.04(a)(3) (A lawyer shall not “engage in conduct involving
dishonesty, fraud, deceit[,] or misrepresentation”). The Fifth Circuit, for example,
recently approved a $2,500 sanction for AI hallucinated misrepresentations. Fletcher
v. Experian Info. Sols., Inc., 168 F.4th 231 (2026).
binding and materially dissimilar. Neither of these cases therefore carry
Plaintiffs’ burden. The Court has little patience for such “lazy
lawyering.”
The remaining two cases, Tennessee v. Garner, 471 U.S. 1 (1985) and
Graham v. Connor, 490 U.S. 386 (1989), fare no better. Plaintiffs argue
that Garner clearly establishes that non-deadly force against a
compliant, non-threatening person is unreasonable. ECF No. 18 at 7.
But this formulation asks too much of Garner. In Garner, police officers
pursued and shot a fleeing purse-snatcher. 471 U.S. at 4. At most, the
5th Circuit has noted, Garner stands for the proposition that deadly
force is prohibited against an unarmed burglary suspect fleeing on foot
who poses no immediate threat. Harmon v. City of Arlington, 16 F.4th
1159, 1167 (5th Cir. 2021). It simply does not follow that because deadly
force is unreasonable under those circumstances, non-deadly force (like
a taser) must be too. Cf. ECF. No 18 at 7. That inference gets the
reasoning precisely backward and is the kind of defective, over-
generalized extension that the Supreme Court has repudiated. See, e.g.,
Kisela v. Hughes, 584 U.S. 100, 105 (2018) (rejecting use of broad
formulation of Garner’s holding).
Graham v. Connor does not help Plaintiffs either. In Graham, the
Court held that the question of excessive force requires “requires careful
attention to the facts and circumstances of each particular case,
including the severity of the crime at issue, whether the suspect poses
an immediate threat to the safety of the officers or others, and whether
he is actively resisting arrest or attempting to evade arrest by flight.”
Graham v. Connor, 490 U.S. 386, 396 (1989). There, officers applied
force to a diabetic detained during an investigative stop that resulted in
a broken foot, cuts on his wrists, a bruised forehead, and an injured
shoulder. Id. at 390. But the Court cautioned that “officers are often
forced to make split-second judgments––in circumstances that are
tense, uncertain, and rapidly evolving––about the amount of force that
is necessary in a particular situation.” Id. at 396. The reasonableness of
force required, therefore, should be “judged from the perspective of a
reasonable officer on the scene, rather than with the 20/20 vision of
hindsight.” Id. at 397.
Here, the Court need not, and does not, decide whether Jackson
violated the Fourth Amendment when he used force against Plaintiffs.
For even assuming a Fourth Amendment violation occurred—a
proposition that is not at all evident—Plaintiffs’ desired principle simply
cannot be extracted from Garner with sufficient clarity to constitute
“clearly established” law. Cf. ECF. No. 18 at 7 (misconstruing Garner to
stand for the proposition that application of force against a compliant,
non-threatening person is always objectively unreasonable).
In any event, the Supreme Court has noted that “Garner and
Graham do not by themselves create clearly established law outside an
‘obvious case.’” White v. Pauly, 580 U. S. 73, 80 (2017) (internal
quotation marks omitted). And while undoubtedly “obvious” excessive
force cases can arise, they are extremely rare. See, e.g., Taylor v. Riojas,
141 S. Ct. 52, 54 (2020) (per curiam) (noting that to qualify as an
“obvious” case, there must be (1) particularly egregious facts and (2) no
evidence that the officials’ actions were compelled by necessity or
exigency). The facts alleged here involving a single taser discharge
against a non-compliant adult are not so egregious as to be an obvious
case.
The “clearly established” inquiry is demanding, especially in claims
for excessive force. Morrow v. Meachum, 917 F.3d 870, 874 (5th Cir.
2019). Qualified immunity protects “all but the plainly incompetent or
those who knowingly violate the law.” Malley v. Briggs, 475 U.S. 335,
341, 106 (1986). Here, Plaintiffs failed to identify any clearly established
law that would place beyond doubt the constitutional question in this
case. As a result, their excessive force claim cannot succeed.
Finally, while it is true that an officer who is present at the scene
and does not take reasonable measures to protect a suspect from another
officer's use of excessive force may be liable under Section 1983, Hale v.
Townley, 45 F.3d 914, 919 (5th Cir. 1995), this claim rises and falls with
Plaintiffs’ claim against Officer Jackson. If Plaintiffs do not plausibly
allege that clearly establish law forbids Officer Jackson’s actions, then
a fortiori they have not proved that bystanding officers were not entitled
to immunity. Put otherwise, if a reasonable official would not have
understood that his conduct violated the Fourth Amendment, neither
would a reasonable bystander. Accordingly, Plaintiffs’ claim for
bystander liability by excessive force are also barred.
B. Plaintiffs Do Not Plausibly Allege Municipal Liability
Plaintiffs’ complaint presses two theories of municipal liability. First,
Plaintiffs allege that DFW had a “custom and practice” of using
excessive force against compliant individuals. ECF No. 2 at 12. Second,
Plaintiffs allege that DFW failed to train officers who violated
constitutional rights. ECF No. 2 at 12. Neither claim survives.3
1. Plaintiffs Do Not Plausibly Allege Custom and Practice
A governmental entity may only be held liable in a Section 1983 suit
when the complained-of constitutional injury, here the use of excessive
force, results from “execution of a government’s policy or custom.”
Monell v. Dep’t of Social Servs., 436 U.S. 658, 694 (1978). Per Monell,
“municipal liability under § 1983 requires proof of three elements: [1] a
policymaker; [2] an official policy; and [3] a violation of constitutional
rights whose ‘moving force’ is the policy or custom.” Id. at 694. To
proceed beyond the pleading stage, a complaint’s “description of a policy
or custom and its relationship to the underlying constitutional violation
. . . cannot be conclusory; it must contain specific facts.” Spiller v. City
of Tex. City, Police Dep’t, 130 F.3d 162, 167 (5th Cir. 1997).
The problem is that Plaintiffs do not plausibly allege any official
policy or custom at all. The second element—an official policy—includes
“[a] policy statement, ordinance, regulation, or decision that is officially
adopted and promulgated by the municipality’s lawmaking officers or by

3 Plaintiffs sue both DFW Airport Department of Public Safety (“DPS”) and DFW
International Airport Board (‘the Board”). For Plaintiffs to sue a department of a city,
that department must enjoy a separate legal existence. Darby v. Pasadena Police Dep’t,
939 F.2d 311, 313 (5th Cir. 1991). But as Defendants note, DFW DPS does not “enjoy
a separate legal existence” from the city. ECF No. 10 at 17. The capacity of an entity
to be sued is determined “by the law of the state where the court is located.” FED. R.
CIV. P. 17(b); see also Darby 939 F.2d at 313. Unless the political entity that created
the department has taken “explicit steps to grant the servient agency with jural
authority,” the department lacks the capacity to sue or to be sued. Id. Plaintiffs’ do not
allege separate jural authority and, in any event, concede this point in their Reply.
ECF No. 18 at 9. Even assuming arguendo that they are separate entities, Plaintiffs
have not plausibly alleged Monell liability against either entity and thus both claims
should be dismissed.
an official to whom the lawmakers have delegated policy-making
authority.” Webster v. City of Houston, 735 F.2d 838, 841 (5th Cir. 1984)
(en banc) (per curiam). But the complaint does not identify a single
official policy to supply the requisite moving force behind the alleged
violation. ECF No. 2.
True, an official policy may also be “[a] persistent, widespread
practice of city officials or employees, which, although not authorized by
officially adopted and promulgated policy, is so common and well settled
as to constitute a custom that fairly represents municipal policy” and
“practically have the force of law.” Id; see also Connick v. Thompson, 563
U.S. 51, 61 (2011). But Plaintiffs do not plead that DFW maintained a
policy of widespread and persistent use of excessive force. Nowhere in
the complaint do Plaintiffs allege other incidents of excessive force or
misuse of taser. The only oblique reference to a pattern is that the “police
regularly encounter non-criminal customer service disputes,” ECF No.
18 at 9, and a threadbare recitation in the complaint of a “custom and
practice of using excessive force against compliant individuals.” ECF No.
2 at 9. But, as the Fifth Circuit has noted, “if actions of city employees
are to be used to prove a custom for which the municipality is liable,
those actions must have occurred for so long or so frequently that the
course of conduct warrants the attribution to the governing body of
knowledge that the objectionable conduct is the expected, accepted
practice of city employees.” Webster v. City of Houston, 735 F.2d 838, 842
(5th Cir. 1984). Plaintiffs’ conclusory statements without additional
factual enhancement do not come close to plausibly alleging the custom
or policy required for municipal liability.
2. Plaintiff’s Do Not Plausibly Allege a Failure to Train
Neither have Plaintiffs plausibly pleaded that DFW’s allegedly
inadequate training or supervision of Officer Jackson was a moving force
behind the supposed constitutional violation. To establish municipal
liability under a failure-to train theory, Plaintiffs must prove three
elements: 1) the city failed to train or supervise the officers involved; 2)
there is a causal connection between the alleged failure to supervise or
train and the alleged violation of the plaintiff’s rights; and 3) the failure
to train or supervise constituted deliberate indifference to the plaintiff’s
constitutional rights. Hutcheson v. Dallas Cnty., 994 F.3d 477, 482 (5th
Cir. 2021). Plaintiffs argue that DFW failed to establish adequate
policies governing taser deployment, to train in de-escalation, and to
discipline or supervise officers, ECF No. 2 at 9, and that this amounted
deliberate indifference to the need for better training and supervision.
ECF No. 2 at 13. Specifically, Plaintiffs seize on Officer Jackson’s fellow
officer’s statement “No, No, it’s good, we got this” to demonstrate
inadequate training and supervision. ECF No. 2 at 13. But this does not
work either.
In Littell v. Houston Independent School District 894 F.3d 616 (5th
Cir. 2018), the Fifth Circuit clarified the two means of proving municipal
liability under a failure-to-train theory outlined by the Supreme Court
in City of Canton v. Harris 489 U.S. 378 (1989). The first is when
violations are so frequent that the factfinder can infer the need for
further training was obvious to policymakers. Littell, 894 F.3d at 624.
But as noted above, Plaintiffs have not alleged a pattern. However, even
absent proof of pattern, the Court noted that deliberate indifference can
still be inferred if the factfinder determines that the risk of
constitutional violations was or should have been an “obvious” or “highly
predictable consequence” of the alleged training inadequacy. Id.
Presumably, Plaintiffs rely on the latter single-incident theory.
Yet Plaintiffs do not plausibly plead that DFW was deliberately
indifferent to the need for further training. The single-incident theory is
generally reserved for those cases in which the government actor was
provided with no training whatsoever. Peña v. City of Rio Grande City,
879 F.3d 613, 624 (5th Cir. 2018). Further, “[a] municipality’s culpability
for a deprivation of rights is at its most tenuous where a claim turns on
a failure to train.” Connick v. Thompson, 563 U.S. 51, 61 (2011).
For one, Plaintiffs’ threadbare allegations argue as to the extent of
training, not that officers lack training whatsoever. ECF No. 2 at 13.
But even more fundamentally, Plaintiffs offer no factual support for
these contentions other than Officer Jackson’s fellow officer’s statement
that “no, no, we got this.” ECF. No 2 at 13. This statement alone,
however, cannot support the inference plaintiff desires. Even supposing
that his admonition to his fellow officer indicates disapproval of the
technique, the lone statement does not plausibly support inadequate
training. The statement could just as well indicate that officers had
received training and therefore disapproved. But the statement and
accompanying threadbare conclusions do not “allege with specificity how
a particular … program is defective.” Zarnow v. City of Wichita Falls,
614 F. 3d 161, 170 (5th Cir. 2020). Nor do they approach deliberate
indifference, which “requires a showing of more than negligence or even
gross negligence.” Est. of Davis ex rel. McCully v. City of N. Richland
Hills, 406 F.3d 375, 381 (5th Cir. 2005). Plaintiffs thus also fail to
plausibly allege municipal liability under a failure-to-train theory.
C. The Court Declines to Exercise Supplemental jurisdiction
Over Plaintiffs’ State Law Claims
Because the Plaintiffs’ constitutional claims are barred by qualified
immunity and foreclosed under Monell, and thus should be dismissed,
only the state law claims remain. Those too should be dismissed.
Under 28 U.S.C. § 1367(c), a court may decline to exercise
supplemental jurisdiction over a state law claim if the district court has
dismissed all claims over which it has original jurisdiction. We are also
guided by “considerations of judicial economy, convenience, fairness,
and comity.” Mendoza v. Murphy, 532 F.3d 342, 346 (5th Cir. 2008)
(citing McClelland v. Gronwaldt, 155 F.3d 507, 519 (5th Cir. 1998),
overruled on other grounds by Arana v. Ochsner Health Plan, 338 F.3d
433 (5th Cir. 2003)). Our general rule is to dismiss state law claims when
the federal claims to which they are pendent are dismissed. Parker &
Parsley Petrol. Co. v. Dresser Indus., 972 F.2d 580, 585 (5th Cir. 1992).
However, we review each claim “on a case-by-case basis, and no single
factor is dispositive.” Mendoza, 532 F.3d at 346.
Here, considerations of judicial economy, convenience, fairness, and
comity support dismissal. It would serve the important interests of
federalism and comity, because federal courts are courts of limited
jurisdiction that “often are not as well equipped for determinations of
state law as are state courts.” Parker, 972 F.2d at 588–89. Plaintiffs’
state law claims, though themselves subject to serious jurisdictional
hurdles, nevertheless involve interpretation of state law and further
factual development that is best left to state court.
CONCLUSION
For the above reasons, the Court GRANTS Defendants’ Motion to
Dismiss as to the Section 1983 claims with prejudice and dismisses
the state law claims without prejudice so they can be pursued in
Texas state court.
SO ORDERED on this 27th day of August 2026.

Mark T. Pittman
UNITED STATES DISTRICT JUDGE

12

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11428752. Public record. Not legal advice.