The Fifth Circuit Court of Appeals affirmed a district court ruling granting qualified immunity to Dallas County Jail Officer Annette Grant in a wrongful death lawsuit filed by Sophia Lewis, the mother of an inmate who died while in pretrial detention.
Shamond Lewis was arrested for aggravated assault on September 22, 2022, and booked into the Dallas County Jail as a pretrial detainee. He died during his detention in circumstances that led his mother to file an excessive force lawsuit under Section 1983, claiming violations of his Fourteenth Amendment rights.
The case centers on disputed facts about how Officer Grant used her body weight during an incident with Lewis. According to court documents, the specific details of whether, where, and how Grant applied her body weight to Lewis remained contested throughout the litigation. Sophia Lewis brought the lawsuit both individually and as the representative of her son's estate, naming Grant as the primary remaining defendant on appeal.
The legal proceedings began in the U.S. District Court for the Northern District of Texas, where Grant moved for summary judgment based on qualified immunity protections. The doctrine of qualified immunity shields government officials from civil liability unless they violated clearly established statutory or constitutional rights that a reasonable person would have known about.
Despite the district court's obligation to view all facts in the light most favorable to the plaintiff, the court ruled in favor of Officer Grant. The trial court determined that even if Grant's actions violated Lewis's constitutional rights, any such violation was not clearly established under existing law at the time of the incident.
The case then proceeded to the Fifth Circuit Court of Appeals, where a three-judge panel consisting of Circuit Judges Higginbotham, Ho, and Douglas reviewed the district court's decision. In a per curiam opinion filed January 28, 2026, the appeals court agreed with the lower court's analysis and affirmed the grant of qualified immunity.
The Fifth Circuit's opinion focused on the "clearly established" prong of qualified immunity analysis. Under Supreme Court precedent, for a constitutional right to be clearly established, existing case law must have given defendants fair warning that their conduct was unconstitutional. The law must be sufficiently clear so that every reasonable official would understand that what he or she was doing violated federal law.
The appeals court found that the specific circumstances of Grant's alleged use of force against Lewis did not violate clearly established law as it existed in September 2022. This finding allowed the court to grant qualified immunity without determining whether Grant's actions actually violated the Constitution, as courts may resolve qualified immunity cases on either prong of the analysis.
The decision represents another example of courts applying qualified immunity protections in cases involving deaths in custody. The doctrine has been subject to ongoing debate, with critics arguing it provides too much protection for government officials and makes it difficult for families to obtain justice when constitutional rights are violated.
For pretrial detainees like Lewis, constitutional protections against excessive force arise under the Fourteenth Amendment's Due Process Clause rather than the Eighth Amendment's prohibition on cruel and unusual punishment, which applies to convicted prisoners. The legal standard for pretrial detainees requires showing that officials acted with deliberate indifference to serious medical needs or used force that was objectively unreasonable.
The specific circumstances surrounding Lewis's death and the disputed facts about Officer Grant's use of force highlight the challenges families face in pursuing civil rights claims against jail personnel. Even when deaths occur in custody, qualified immunity can shield officers from liability if existing case law has not clearly established that their specific conduct was unconstitutional.
The Fifth Circuit's unpublished opinion will not serve as binding precedent for future cases, as noted in the court's designation that the opinion is not for publication under Fifth Circuit Rule 47.5. However, the decision adds to the body of qualified immunity jurisprudence in cases involving deaths in custody.
The ruling concludes the federal court proceedings in Lewis v. Grant, with the qualified immunity determination effectively ending the civil rights lawsuit against Officer Grant. The decision underscores the high bar plaintiffs face when challenging government officials' conduct under Section 1983, particularly in cases where the specific factual circumstances have not been previously addressed by clearly established precedent.