Williams v. Town of Clinton

United States Court of Appeals
for the Fifth Circuit
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No. 26-30139
Summary Calendar
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Maurice Williams,

Plaintiff—Appellant,

versus

Town of Clinton; Charles Brown, Individually,

Defendants—Appellees.
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Appeal from the United States District Court
for the Middle District of Louisiana
USDC No. 3:23-CV-119
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Before Haynes, Graves, and Ramirez, Circuit Judges.
Per Curiam:
*

Following his arrest by a Town of Clinton, Louisiana (the “Town”),
police officer, Maurice Williams filed federal and state claims against the
Town and the officer. The district court dismissed all claims. As explained
below, we AFFIRM.
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*
This opinion is not designated for publication. See 5th Cir. R. 47.5.
United States Court of Appeals
Fifth Circuit
FILED
August 17, 2026

Lyle W. Cayce
Clerk
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I. Background
In October 2021, Officer Charles Brown of the Town’s police
department issued Williams a misdemeanor summons under the Town’s
“dogs not to run at large” ordinance, with a court date of December 7, 2021.
Though Williams did not attend because he claims he was unable to appear
in response to this summons because the court was not in session on that day,
a warrant was issued for Williams’s arrest for failure to appear.
On February 28, 2022, the district attorney contacted Williams to
inform him of the warrant. On the morning of March 2, Officer Brown went
to Williams’s residence to execute the warrant and arrest Williams. Williams
alleges that the following occurred during execution of the arrest:
Officer Brown needlessly pepper[-]sprayed Williams, beat
Williams, and caused serious bodily harm to Williams’[s] neck.
Officer Brown grabbed [Williams’s] left hand and shoved it in
between his shoulder blades, slammed his face into a door,
injuring his head, all while [Williams] was barefoot and with a
cast on one arm. [Williams] did not resist arrest, and at age 70,
would be no threat to an officer.
In February 2023, Williams filed suit in federal court against the Town
and Officer Brown in his individual capacity. After the district court
dismissed various claims in the original complaint, Williams filed an amended
complaint asserting claims under 42 U.S.C. § 1983 for false arrest, illegal
seizure and excessive force,
1
and malicious prosecution and, under state law,
for battery, false arrest, defamation, and malicious prosecution.
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1
Williams’s amended complaint refers to this claim as “illegal seizure and
excessive force” once, otherwise addressing only excessive force. While the district court
acknowledges Williams’s claim of “illegal seizure and excessive force,” it also goes on to
only address excessive force. Williams’s briefing does the same, and it seems to clear up
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Defendants moved for summary judgment as to all claims, arguing
that they were entitled to judgment as a matter of law for all claims and that
Officer Brown was entitled to qualified immunity. The district court granted
summary judgment on the federal and state false arrest claims, federal and
state malicious prosecution claims, and state defamation claim. It denied
summary judgment on the federal excessive force claim against the Town and
on the state battery claim against both defendants, but it granted summary
judgment on the federal excessive force claim against Officer Brown because
it found he was entitled to qualified immunity such that this issue was not
available against the Town. The district court declined to exercise
supplemental jurisdiction over the remaining state law claims. The district
court entered a final judgment disposing of all claims, and Williams promptly
appealed.
II. Jurisdiction & Standard of Review
The district court had jurisdiction over this case under 28 U.S.C.
§§ 1331 and 1343 because Williams brought claims under 42 U.S.C. § 1983.
We have jurisdiction over this appeal under 28 U.S.C. § 1291 because the
district court entered a final judgment.
“We review a district court’s grant of summary judgment de novo,
applying the same standards as the district court.” Hagen v. Aetna Ins. Co.,
808 F.3d 1022, 1026 (5th Cir. 2015). We also review de novo a district court’s
determination of entitlement to qualified immunity. Trammell v. Fruge, 868
F.3d 332, 338 (5th Cir. 2017).
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this issue by addressing the constitutionality and reasonableness of a seizure in the context
of alleged excessive force. As such, we address this claim as an excessive force claim.
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III. Discussion
On appeal, Williams argues that the district court erred in:
(A) granting Officer Brown qualified immunity as to Williams’s § 1983
excessive force claim, and (B) granting summary judgment on Williams’s
false arrest and malicious prosecution claims under federal and state law. We
address each argument in turn.
2

A. Qualified Immunity
First, Williams argues that the district court erred in granting Officer
Brown qualified immunity as to his § 1983 excessive force claim.
3
We
disagree.
Once a defendant pleads qualified immunity, the burden on summary
judgment “then shifts to the plaintiff, who must rebut the defense by
establishing a genuine fact issue as to whether the official’s allegedly
wrongful conduct violated clearly established law.” Trammell, 868 F.3d at
338 (citation omitted). The two-part inquiry asks “first, whether taken in the
light most favorable to the party asserting the injury, the facts alleged show
the officer’s conduct violated a constitutional right; and second, whether the
right was clearly established.” Id. at 339 (citation modified).
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2
The Town argues that its “liability is wholly derivative, and only the state law
claims reach it on appeal. Because we don’t have to reach that argument, we do not address
it.
3
While Williams states that the district court found both defendants entitled to
qualified immunity, it only did so as to Officer Brown. This was proper, as qualified
immunity only applies to individual state officials. See Stidham v. Tex. Comm’n on Priv. Sec.,
418 F.3d 486, 490 (5th Cir. 2005) (“Qualified immunity shields state officials from
personal suits when they act in their official capacity[.]”). Of course, as a result, the Town
is not in Monell.
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The district court found that Williams did not meet his burden, as
Williams’s “conclusory allegation that Brown acted with malice” was
insufficient. We agree with the district court that Officer Brown is entitled
to qualified immunity.
B. Summary Judgment
Second, Williams argues that the district court erred in granting
summary judgment regarding Williams’s false arrest and malicious
prosecution claims. But again, we agree with the district court.
Summary judgment is proper “if the movant shows that there is no
genuine dispute as to any material fact and the movant is entitled to judgment
as a matter of law.” Fed. R. Civ. P. 56(a).
We address summary judgment as to each claim in turn.
1. False arrest
The district court denied Williams’s federal and state false arrest
claims because “[Officer] Brown conducted the arrest pursuant to a facially
valid bench warrant.” We agree. Under federal law, “[i]f there was probable
cause for any of the charges made[,] then the arrest was supported by
probable cause, and the claim for false arrest fails.” Deville v. Marcantel, 567
F.3d 156, 164 (5th Cir. 2009) (per curiam) (citation modified). Likewise,
under Louisiana law, “[a] facially valid arrest warrant immunizes the officers
from false arrest and imprisonment claims.” Id. at 172.
As such, summary judgment as to the false arrest claims was proper.

2. Malicious prosecution
We also agree with the district court’s decision to grant summary
judgment concerning Williams’s federal and state malicious prosecution
claims.
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Because the elements of a § 1983 malicious prosecution claim and the
elements of a Louisiana state malicious prosecution claim are “coextensive,”
Armstrong v. Ashley, 60 F.4th 262, 279 (5th Cir. 2023) (citation omitted), we
analyze them simultaneously. In this circuit, the plaintiff must show:
(1) the commencement or continuance of an original criminal
proceeding; (2) its legal causation by the present defendant
against plaintiff who was defendant in the original proceeding;
(3) its bona fide termination in favor of the present plaintiff;
(4) the absence of probable cause for such proceeding;
(5) malice; and (6) damages.
Espinal v. City of Hou., 96 F.4th 741, 748 (5th Cir. 2024).
Because, for the same reasons as above, we find that the arrest was
supported by probable cause, Williams failed to show a genuine dispute of
material fact as to the fourth element, and summary judgment was
appropriate.
IV. Conclusion
Accordingly, we AFFIRM.
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