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Caffey v. Domingue

United States District Court, W.D. Louisiana, Lafayette Division

April 23, 2018

CARL L. CAFFEY, ET AL.
v.
LONIS D. DOMINGUE, SR., ET AL.

          MEMORANDUM RULING

          PATRICK J HANNA UNITED STATES MAGISTRATE JUDGE

         Currently pending before the court is the motion for partial summary judgment filed by the plaintiffs, Carl L. Caffey and Cynthia C. Caffey. (Rec. Doc. 57). The motion is opposed, and oral argument was held on March 22, 2018. Considering the evidence, the law, and the arguments of the parties, and for the reasons fully explained below, the motion is DENIED.

         Background

         In this lawsuit, Mr. and Mrs. Caffey claim that Mr. Caffey sustained serious injuries when he was handcuffed by Acadia Parish Sheriff's Deputy Lonis Domingue after being arrested on October 16, 2009. The Caffeys own a trailer park, located on land adjacent to their home. One of their tenants, Caroline Eaglin, was moving her trailer out of the trailer park, and Mr. Caffey was concerned that moving the trailer would damage his property. Ms. Eaglin's daughter called the Acadia Parish Sheriff's Office and complained that Mr. Caffey was harassing her mother. Deputy Domingue, who had responded to a prior call involving Mr. Caffey and Ms. Eaglin, arrived at the scene, arrested Mr. Caffey for disturbing the peace and public intimidation of a police officer, handcuffed Mr. Caffey, and took him to the Sheriff's Office. The plaintiffs claim that Deputy Domingue lacked probable cause to arrest Mr. Caffey for anything, they claim that he was unlawfully seized, and they claim that excessive force was used in applying the handcuffs during the arrest. The plaintiffs claim that Deputy Domingue applied the handcuffs too tightly, that he failed to double-lock them (which would have prevented them from tightening up while being worn), and that he failed to loosen the handcuffs when Mr. Caffey complained that they were too tight. Deputy Domingue, however, does not recall whether he double-locked the handcuffs nor does he recall Mr. Caffey complaining that the cuffs were too tight. It is undisputed that the handcuffs injured Mr. Caffey's right wrist.

         Analysis

         A. The Summary Judgment Standard

         Under Rule 56(a) of the Federal Rules of Civil Procedure, summary judgment is appropriate when there is no genuine dispute as to any material fact, and the moving party is entitled to judgment as a matter of law. A fact is material if proof of its existence or nonexistence might affect the outcome of the lawsuit under the applicable governing law.[1] A genuine issue of material fact exists if a reasonable jury could render a verdict for the nonmoving party.[2]

         The party seeking summary judgment has the initial responsibility of informing the court of the basis for its motion and identifying those parts of the record that demonstrate the absence of genuine issues of material fact.[3] If the moving party carries its initial burden, the burden shifts to the nonmoving party to demonstrate the existence of a genuine issue of a material fact.[4] All facts and inferences are construed in the light most favorable to the nonmoving party.[5]

         If the dispositive issue is one on which the nonmoving party will bear the burden of proof at trial, the moving party may satisfy its burden by pointing out that there is insufficient proof concerning an essential element of the nonmoving party's claim.[6] The motion should be granted if the nonmoving party cannot produce evidence to support an essential element of its claim.[7]

         B. The Standard for Evaluating a Section 1983 Claim

         The plaintiffs brought their claims under 42 U.S.C. §§ 1983 and 1988 as well as under Louisiana law. Section 1983 provides a cause of action against anyone who “under color of any statute, ordinance, regulation, custom, or usage, of any State” violates another person's Constitutional rights. Section 1983 is not itself a source of substantive rights; it merely provides a method for vindicating federal rights conferred elsewhere.[8] To state a section 1983 claim, a plaintiff must: (1) allege a violation of a right secured by the Constitution or laws of the United States, and (2) demonstrate that the alleged deprivation was committed by a person acting under color of state law.[9] In this case, the defendants do not contest whether Deputy Domingue acted under color of law at any relevant time, but they do challenge whether his actions or omissions are Constitutional violations.

         C. Genuine Issues of Material Fact Preclude Summary Judgment

         As a pretrial detainee, Mr. Caffey had a Fourteenth Amendment due process right to be free from excessive force.[10] The law is clearly established that a law enforcement officer's use of excessive force in the course of an arrest, investigatory stop, or other “seizure” of a free citizen violates that citizen's constitutional rights.[11] To succeed on an excessive force claim, a plaintiff bears the burden of showing (1) an injury (2) that resulted directly and only from the use of force that was excessive to the need and (3) that the force used was objectively unreasonable.[12] Although it is no longer necessary for a plaintiff to establish that he sustained a significant injury, a plaintiff is required to establish that he sustained at least some form of injury that is more than de minimis when evaluated in the context in which the force was deployed.[13] This proposition was very recently clarified by the Fifth Circuit on April 12, 2018:

The district court concluded that Sam's injuries were de minimis and therefore could not support an excessive force claim. This was error. In Alexander v. City of Round Rock, we reversed dismissal of an excessive force claim. 854 F.3d 298, 310 (5th Cir. 2017). In doing so, we explained that even insignificant injuries may support an ...

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