The Fifth Circuit Court of Appeals affirmed a lower court's decision dismissing wrongful death claims against the City of Monroe, Louisiana, and other defendants in a case involving David Harris, who died while in police custody.
In a per curiam opinion filed Jan. 26, the three-judge panel upheld the U.S. District Court for the Western District of Louisiana's grants of summary judgment in favor of all defendants. The case, *Green v. City of Monroe*, involved multiple survivors of Harris who brought state and federal wrongful death claims following his death in police custody.
The plaintiffs—David Green, LaDaizya Tillman, Dakedra Jones, Ladaveon McFee, Daijour McFee, Debra Bailey on behalf of her minor child J.B., and David Ruff—sued the City of Monroe, two individual police officers Lawrence Moore and Russell McCall, and BRFHH Monroe, L.L.C., which operates as Ochsner LSU Health-Monroe hospital.
According to court records, officers initially sought medical treatment for Harris at the hospital, though the opinion provides limited details about the circumstances surrounding his death or the specific nature of the medical care provided.
The district court had granted separate summary judgment motions in favor of each defendant, finding that the plaintiffs failed to demonstrate any material disputes of fact that would warrant a trial. Under federal civil procedure rules, summary judgment is appropriate when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law.
The survivors' lawsuit, originally filed in 2022 as case number 3:22-CV-884, alleged various wrongful death claims under both state and federal law. While the specific legal theories were not detailed in the appeals court opinion, such cases typically involve claims under 42 U.S.C. Section 1983 for federal civil rights violations, as well as state law claims for wrongful death, negligence, and potentially excessive force.
Cases involving deaths in police custody often raise questions about use of force, medical care, and constitutional protections. The involvement of a hospital as a defendant suggests the case may have included allegations related to medical treatment or failure to provide adequate care.
The Fifth Circuit panel, consisting of Chief Judge Jennifer Walker Elrod and Circuit Judges Jerry E. Smith and Don R. Willett, heard oral arguments before issuing their decision. In their brief per curiam opinion, the judges concluded that the district court "thoroughly considered the case brought by the plaintiffs, fairly considered defendants' defenses to the various claims, and committed no reversible error in its decisions."
Per curiam opinions, issued by the court as a whole rather than authored by a single judge, are typically used for cases where the legal issues are straightforward or the court's reasoning follows established precedent. This opinion was designated as unpublished, meaning it will have limited precedential value for future cases.
The affirmance represents a complete victory for the defendants, as the appeals court found no basis to disturb any aspect of the district court's rulings. For the plaintiffs, the decision effectively ends their legal challenge unless they seek further review.
The plaintiffs could potentially petition the Supreme Court for a writ of certiorari, though the high court accepts only a small percentage of such petitions and typically focuses on cases that present novel legal questions or conflicts between circuit courts.
Police custody death cases have received increased attention in recent years, particularly following high-profile incidents nationwide. These cases often involve complex questions about the use of force, medical care in custody, and the scope of constitutional protections for individuals in police custody.
The involvement of Monroe, Louisiana, adds this case to ongoing scrutiny of policing practices in the region. Louisiana has faced various federal investigations and consent decrees related to police practices in different jurisdictions.
For the City of Monroe, the decision provides finality on potential liability exposure from Harris's death. Municipal defendants in such cases often face significant financial exposure from successful wrongful death claims, making favorable summary judgment rulings valuable for budget planning and insurance considerations.
The hospital's successful defense may reflect the complex interplay between law enforcement and medical providers when officers bring suspects or arrestees for treatment. Healthcare providers generally have duties to provide appropriate medical care, but the specific obligations and potential liability can vary based on the circumstances.
The case underscores the challenges plaintiffs face in police custody death litigation, where defendants often have qualified immunity protections and where establishing the specific factual and legal elements required for liability can prove difficult without clear evidence of constitutional violations or negligence.