The Fifth Circuit has affirmed a judgment in favor of Harris County and three deputy constables in a civil rights lawsuit filed by a groom and his guest who was arrested during a wedding reception.
During the reception the groom’s father began loudly complaining when the bartender decided to stop serving alcohol because the bartender “noticed a significant number of guests who were dressed slopp[ily], slurring their words and stumbling.” According to witnesses the groom’s father “struck or pushed” a plain clothes deputy constable who was working security at the event. When a uniformed deputy constable who was also working off duty began escorting the father from the room his son, a deputy sheriff, came to his aid along with thirty to forty other people. The constable ordered party goers to move away and to leave the premises. A guest who was also a deputy sheriff refused to leave.
The groom was arrested for interfering with public duties, his father for assault, and the guest, for criminal trespass. All were taken to jail. A Harris County Criminal Court judge found probable cause.
The groom and the wedding guest brought a Section 1983 lawsuit claiming that the deputy constables did not have probable cause to arrest them, that the supervisor failed to properly train and supervise them, and that Harris County enacted unconstitutional practices and customs.
The panel affirmed the district court’s holding that the independent-intermediary doctrine barred the claims against the deputy constables. Under that doctrine, if facts supporting an arrest are placed before an independent intermediary such as a magistrate or grand jury, the intermediary’s decision breaks the chain of causation for a claimed Fourth Amendment violation. Because the plaintiffs were brought before a judge who found there to be probable cause for their detention they could not bring a claim against the deputy or her supervisors.
The appellate court also affirmed the judgment in favor of Harris County finding that because there was no constitutional violation arising from the actions of the individual defendants Harris County could not be liable under Section 1983.
The case is Lock v Harris County.