The Fifth Circuit Court of Appeals affirmed a district court ruling that granted qualified immunity to League City police officers who tackled a man to the ground, causing serious head injuries, after he allegedly became physically aggressive during an encounter in May 2022.
The court issued its decision Jan. 7 in *Perdomo v. City of League City, Texas* (5th Cir. 2026), rejecting plaintiff Yoni Orli Perdomo's appeal of the U.S. District Court for the Southern District of Texas's dismissal of his excessive force claims against Officers Trevor Rector and Tanner Surrat, along with the City of League City and its police department.
Circuit Judge Edith H. Jones wrote for the three-judge panel that the officers acted reasonably under the circumstances, noting that video evidence showed Perdomo being "aggressive, rather than compliant, in the moments before the injury."
The incident occurred in May 2022 when Perdomo, who worked as a subcontractor on a residential remodeling project in League City, Texas, returned to the job site after being terminated by the general contractor. According to court documents, Perdomo came back to the site allegedly to retrieve his tools.
The confrontation escalated when Perdomo "repeatedly slammed his body into" Officer Rector, the appeals court opinion states. In response, Officer Rector tackled Perdomo to the ground. During the takedown, Perdomo's head struck a concrete sidewalk, resulting in serious injuries.
Perdomo filed a federal civil rights lawsuit under Section 1983, alleging that the officers used excessive force in violation of the Fourth Amendment. The plaintiff claimed the officers' actions were unreasonable and sought damages for his injuries.
The district court disagreed, concluding that the defendant officers acted reasonably under the circumstances and were entitled to qualified immunity, a legal doctrine that protects government officials from liability when their conduct does not violate clearly established law.
Qualified immunity analysis requires courts to determine whether the facts alleged show a constitutional violation and whether the right was clearly established at the time of the incident. If officers' conduct was objectively reasonable, they cannot be held liable even if the plaintiff suffered injuries.
The Fifth Circuit's affirmation focused heavily on the video evidence from the encounter, which the court said depicted Perdomo as the aggressor rather than a compliant individual. The appeals court found this evidence supported the district court's conclusion that the officers' use of force was justified given Perdomo's alleged physical aggression.
The panel consisted of Circuit Judges Edith H. Jones and James E. Engelhardt, along with U.S. District Judge Carl J. Summerhays of the Western District of Louisiana, sitting by designation.
The case highlights the ongoing legal challenges faced by plaintiffs seeking to hold police officers accountable for use of force incidents. Courts consistently apply qualified immunity protections when officers can demonstrate their actions were objectively reasonable responses to perceived threats or resistance.
Video evidence has become increasingly important in these cases, often serving as the decisive factor in determining whether force was justified. In this instance, the court found the video supported the officers' account that Perdomo was physically aggressive, undermining his claims of excessive force.
The decision also underscores the high burden plaintiffs face in excessive force cases. Even when injuries are severe, as in Perdomo's case where he suffered serious head trauma, courts will uphold officers' actions if they determine the force used was proportional to the resistance encountered.
For the City of League City and its police department, the ruling validates their officers' training and response protocols. The decision suggests that when officers face physical resistance, their use of force to control the situation will receive judicial deference, particularly when supported by video evidence.
The case does not appear to establish new legal precedent but rather applies existing qualified immunity doctrine to the specific facts presented. The Fifth Circuit's analysis focused on the objective reasonableness standard established in *Graham v. Connor* (S. Ct. 1989), which requires courts to judge officer conduct from the perspective of a reasonable officer at the scene.
Perdomo has not indicated whether he plans to seek Supreme Court review of the decision. The high court rarely grants certiorari in qualified immunity cases unless they present novel legal questions or conflicts between circuit courts.
The ruling adds to a growing body of Fifth Circuit precedent generally favorable to law enforcement in use of force cases. The appeals court has consistently applied qualified immunity protections broadly, requiring plaintiffs to meet high evidentiary standards to overcome officer immunity claims.
For practitioners in this area, the case reinforces the critical importance of video evidence in excessive force litigation and the challenges plaintiffs face when that evidence appears to contradict their version of events.