The U.S. Court of Appeals for the Fifth Circuit affirmed a district court ruling in *Singh v. City of Greenville, Mississippi* (5th Cir. 2026), rejecting an appeal by three Sikh plaintiffs who sued the city and two municipal officials over alleged civil rights violations.
The case involved plaintiffs Surjit Singh, Santokh Singh, and Satvinder Kaur, who brought suit against the City of Greenville, Mississippi; Martavis Moore, a police officer for the city; and Carl Nichols, the chief fire marshal. The lawsuit originated in the U.S. District Court for the Northern District of Mississippi under case number 4:22-CV-195.
In a brief per curiam opinion filed Jan. 16, the three-judge panel consisting of Circuit Judges Jones, Duncan, and Douglas found no reversible error in the district court's decision. The court wrote that it had "reviewed the briefs, district court opinion, and pertinent portions of the record" before reaching its conclusion.
While the appellate court's opinion was largely summary in nature, the panel did address one specific argument raised by the plaintiffs. The court noted that "one of the plaintiff-appellants' contentions merits further discussion," specifically regarding the plaintiffs' reliance on the district court's reference to *Villareal v. City of Laredo*, a significant Fifth Circuit case decided en banc in 2024.
The *Villareal* case, which dealt with First Amendment protections for citizen journalists and police accountability activists, was cited by the district court in its analysis. The citation appears significant given that *Villareal v. City of Laredo*, 94 F.4th 374, 398 (5th Cir. 2024), was later granted certiorari by the Supreme Court, had its judgment vacated, and was remanded as *Villareal v. Alaniz*.
The Singh case represents part of ongoing litigation involving law enforcement conduct and civil rights protections, particularly affecting minority communities. The involvement of both a police officer and fire marshal as defendants suggests the allegations may have involved multiple city departments or a coordinated response by municipal officials.
The case's origins in 2022 indicate it proceeded through typical federal court litigation timelines, with the district court issuing its decision and the plaintiffs subsequently appealing to the Fifth Circuit. The appellate court's decision to issue a per curiam opinion rather than a signed opinion suggests the panel viewed the legal issues as relatively straightforward or well-settled under existing precedent.
Civil rights litigation against municipalities often involves claims under 42 U.S.C. § 1983, which provides a federal cause of action for violations of constitutional rights committed under color of state law. Such cases frequently involve allegations of excessive force, unlawful detention, discrimination, or violations of First Amendment rights.
The fact that the Fifth Circuit specifically addressed the district court's reliance on *Villareal* suggests this may have been a central issue in the plaintiffs' appeal strategy. The *Villareal* case established important precedent regarding citizen oversight of police activities and First Amendment protections in the law enforcement context.
The timing of the Fifth Circuit's decision is notable given recent developments in civil rights jurisprudence and ongoing national conversations about police accountability and minority rights. The Sikh community has faced various challenges regarding religious expression and discrimination, particularly in contexts involving law enforcement interactions.
The per curiam nature of the opinion means it will not be published or serve as binding precedent, as indicated by the court's notation that "this opinion is not designated for publication" under Fifth Circuit Rule 47.5. This suggests the court viewed the case as applying settled law rather than addressing novel legal questions.
For the plaintiffs, the Fifth Circuit's affirmance represents the end of their federal court challenge unless they choose to petition the Supreme Court for certiorari review. Such petitions are rarely granted, particularly in cases where appellate courts have issued summary affirmances without identifying significant legal issues.
The case also highlights the ongoing challenges faced by civil rights plaintiffs in federal court, where qualified immunity doctrines and other procedural hurdles can make successful litigation difficult. The involvement of multiple city officials suggests the plaintiffs alleged either a pattern of misconduct or coordinated violations of their rights.
The Fifth Circuit's jurisdiction covers Texas, Louisiana, and Mississippi, making its decisions particularly influential for civil rights litigation in the region. The court's affirmance in *Singh* continues the appellate court's pattern of carefully scrutinizing civil rights claims while applying established precedent.
Looking forward, the decision may influence how similar civil rights cases are litigated in the Fifth Circuit, particularly those involving minority plaintiffs and multiple municipal defendants. The court's specific discussion of the *Villareal* precedent suggests ongoing evolution in how courts analyze civil rights claims involving law enforcement conduct.
