The Fifth Circuit Court of Appeals reversed a lower court's decision Tuesday, granting qualified immunity to five Rosenberg, Texas police officers who damaged a dialysis patient's medical stent during a detention that lasted six minutes.
In *Lewis v. Delgado*, the appeals court held that Officers John Delgado, Adam Vasquez, Arthur Love, John Clausen, and Matthew Newport did not violate clearly established law when they handcuffed Michael Lewis during their search for armed suspects in November 2020.
The incident began when the Rosenberg Police Department received a report that a group of armed suspects had pointed a firearm at several bystanders. Police received a description of the suspects' vehicle: a white Dodge Charger with black rims and tinted windows. Less than 10 minutes after the initial report, Officer Adam Vasquez spotted a car matching that description near the location of the reported incident.
Vasquez pulled the vehicle over and radioed for backup. The other four defendant officers—Clausen, Newport, Love, and Delgado—responded to the scene to assist with the stop.
During the six-minute detention, officers handcuffed Lewis, who was apparently in or near the vehicle. The handcuffing process damaged a dialysis-related stent in Lewis's forearm, which had been surgically placed to facilitate his ongoing dialysis treatment.
Lewis and Regina Armstead filed a civil rights lawsuit in the U.S. District Court for the Southern District of Texas, alleging that the officers violated Lewis's Fourth Amendment rights through excessive force and unlawful detention. The plaintiffs sought damages for the injury to Lewis's stent and related medical complications.
The district court refused to grant qualified immunity to the officers at the summary judgment stage, finding that genuine issues of material fact existed regarding whether the officers' actions were reasonable under the circumstances. The lower court's decision would have allowed the case to proceed to trial.
Qualified immunity is a legal doctrine that shields government officials from civil liability unless they violated clearly established statutory or constitutional rights that a reasonable person would have known about. The doctrine requires plaintiffs to demonstrate not only that their constitutional rights were violated, but also that the violation was of clearly established law.
On appeal, the Fifth Circuit applied this two-pronged qualified immunity analysis. Writing for the three-judge panel, Circuit Judge Edith H. Jones concluded that even if the officers' actions constituted a constitutional violation, Lewis could not demonstrate that he had a clearly established right that was violated by the brief handcuffing.
The appeals court emphasized the context in which the detention occurred. Officers were actively searching for armed suspects who had recently been reported pointing firearms at bystanders in the immediate area. The vehicle Lewis was associated with matched the description provided by witnesses, including specific details about the car's color, make, model, and distinguishing features like black rims and tinted windows.
The court noted the brief duration of the detention—just six minutes—and the fact that officers were responding to an active public safety threat involving potentially armed individuals. Under these circumstances, the court found that a reasonable officer would not have known that handcuffing Lewis violated clearly established Fourth Amendment principles.
The decision reflects the Fifth Circuit's typically defendant-friendly approach to qualified immunity cases. The court has consistently applied the doctrine broadly to protect law enforcement officers from civil liability, even in cases involving alleged constitutional violations.
The ruling does not address whether Lewis's Fourth Amendment rights were actually violated, focusing instead on the second prong of qualified immunity analysis—whether any violation involved clearly established law. This approach allows courts to grant immunity without definitively ruling on the underlying constitutional question.
Lewis's medical condition added a unique dimension to the case. Dialysis patients require regular access to surgically implanted devices that allow blood to be filtered through dialysis machines. Damage to these access points can create serious medical complications and interrupt life-sustaining treatment.
However, the court's analysis suggests that the officers' lack of knowledge about Lewis's specific medical condition, combined with the exigent circumstances of their search for armed suspects, insulated them from liability under qualified immunity doctrine.
The decision joins a growing body of Fifth Circuit precedent that has been criticized by civil rights advocates for making it difficult for plaintiffs to overcome qualified immunity defenses. The Supreme Court has faced increasing pressure to reconsider the scope of qualified immunity, with several justices questioning whether the doctrine has expanded beyond its original purpose.
For Lewis and Armstead, the ruling effectively ends their federal civil rights lawsuit against the officers. The case had been pending in federal court since 2022, when it was originally filed as case number 4:22-CV-2593 in the Southern District of Texas.
The panel included Circuit Judges Edith H. Jones, who wrote the opinion, along with Circuit Judges King and Wilson. The unanimous decision was filed Jan. 7, 2026, as case number 24-20484.