September 25th, 2020

US Court of Appeals for the Fifth Circuit Opinions
Arnold v. Williams

Docket: 19-30555
Opinion Date: September 24, 2020
Judge: Jennifer Walker Elrod
Areas of Law: Civil Rights, Constitutional Law

Plaintiff filed suit against defendant under 42 U.S.C. 1983 for violations of various constitutional rights and under Louisiana tort law. In this case, after defendant approached, questioned, and reached to grab plaintiff outside of his home, plaintiff fled, fell off a fence, and dislocated his shoulder. The Fifth Circuit reversed the district court's dismissal of the unreasonable search claim and remanded for the district court to consider qualified immunity before proceeding to the merits of the case. The court stated that details in the complaint make plausible the allegation that defendant's search of the curtilage of plaintiff's home was unreasonable insofar as it infringed on plaintiff's reasonable expectation of privacy and exigent circumstances were lacking. However, the court affirmed the district court's dismissal of the unreasonable seizure claim. The court affirmed the district court's dismissal of plaintiff's remaining section 1983 claims, holding that plaintiff failed to state a false arrest/false imprisonment claim, because he failed to plausibly allege that his ultimate arrest was false; failed to state a claim for malicious prosecution under section 1983 because, as the district court correctly observed, there is no freestanding right under the Constitution to be free from malicious prosecution; and failed to state a claim for a violation of procedural and substantive due process because resort to a generalized remedy under the Due Process Clause is inappropriate where a more specific constitutional provision provides the rights at issue. Furthermore, plaintiff failed to allege a claim under Louisiana law for infliction of emotional distress. Finally, the court affirmed the district court's grant of summary judgment and the three evidentiary rulings appealed by plaintiff.

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