Lillie v. Ruiz et al

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
RAVEN LILLIE,
Plaintiff,
VS.
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CIVIL ACTION NO. 4:21-CV-03740
HECTOR AARON RUIZ, et al.,
Defendants.
MEMORANDUM OPINION AND ORDER
Pending before the Court is Defendant City of Arcola’s Motion for Summary
Judgment (Dkt. 63). After careful consideration of the briefing, the record, and the
applicable law, the Court GRANTS the Motion (Dkt. 63).
I. 	FACTUAL BACKGROUND
This matter arises out of the criminal sexual assault inflicted upon Plaintiff Raven
Lillie (“Lillie”) by Police Officer Hector Aaron Ruiz (“Ruiz”). (Dkt. 63 at p. 9). In short,
Ruiz conducted a traffic stop in which he threatened to take Lillie to jail if she did not
follow him into an abandoned area. (Id. at p. 10). Once in said area, Ruiz forced Lillie to
perform a sex act on him. Id. Later that same day, Lillie filed a report alleging she had been
sexually assaulted by Ruiz. Id. She now brings claims under section 1983 for violations of
her Fourth and Fourteenth Amendment rights against Defendant City of Arcola (“the
City”). See (Dkt. 25).
United States District Court
Southern District of Texas
ENTERED
March 16, 2026
Nathan Ochsner, Clerk
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II. 	PROCEDURAL HISTORY
Lillie initially asserted claims against the City for sexual assault, battery, and false
imprisonment—in addition to her claims for violations of her constitutional rights. (Dkt.
25). The Court thereafter granted in part and denied in part a Motion to Dismiss filed by
the City. (Dkt. 32). As such, only Lillie’s claims under section 1983 remain. Id.
The City originally filed its Motion for Summary Judgment on July 3, 2025,
requesting that the Court dismiss Lillie’s section 1983 claims. (Dkt. 63). Lillie thereafter
filed a Motion for Continuance to Conduct Discovery, and the Court held a hearing on the
motion. (Dkts. 64, 75). Lillie also filed a response to the City’s Motion for Summary
Judgment in the interim, on August 25, 2025. (Dkt. 66). The Court ultimately granted
Lillie’s request and extended the parties’ discovery deadline to October 14, 2025. (Dkt.
75). Lillie filed a supplement to her response on September 5, 2025. (Dkt. 71). The City
was also granted an extension of time to reply to Lillie’s response and timely did so on
September 9, 2025. (Dkts. 70, 72).
As such, all of the briefing currently before the Court was filed prior to the amended
discovery deadline of October 14, 2025. See (Dkts. 63, 66, 71, 72). However, Lillie did not
seek any additional discovery despite receiving the extension. (Dkt. 78 at p. 1). As such,
the City’s summary judgment motion and the subsequent briefing is ripe for ruling as filed.
See id.
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III. 	LEGAL STANDARDS AND APPLICABLE LAW
A. 	Summary Judgment
Federal Rule of Civil Procedure 56 provides that summary judgment is proper when
“there is no genuine dispute as to any material fact and the movant is entitled to judgment
as a matter of law.” F ED. R. C IV. P. 56(a). “A fact is material if it might affect the outcome
of the suit, and a factual dispute is genuine if the evidence is such that a reasonable jury
could return a verdict for the nonmoving party.” Estate of Miranda v. Navistar, Inc., 23
F.4th 500, 503 (5th Cir. 2022). To survive summary judgment, the nonmovant must
“present competent summary judgment evidence to support the essential elements of its
claim.” Cephus v. Tex. Health & Hum. Servs. Comm’n, 146 F. Supp. 3d 818, 826 (S.D.
Tex. 2015).
B. 	42 U.S.C. § 1983
Section 1983 provides a private right of action for the deprivation of rights,
privileges, and immunities secured by the Constitution or laws of the United States. Section
1983 reads in relevant part:
Every person who, under color of any statute, ordinance, regulation,
custom, or usage, of any State or Territory or the District of Columbia,
subjects, or causes to be subjected, any citizen of the United States or
other person within the jurisdiction thereof to the deprivation of any
rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity,
or other proper proceeding for redress.
42 U.S.C. § 1983. “[Section] 1983 ‘is not itself a source of substantive rights,’ but merely
provides ‘a method for vindicating federal rights elsewhere conferred.”’ Graham v.
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Connor, 490 U.S. 386, 393-94 (1989) (quoting Baker v. McCollan, 443 U.S. 137, 144
(1979)).
To establish section 1983 liability, Lillie must prove that she suffered “(1) a
deprivation of a right secured by federal law (2) that occurred under color of state law, and
(3) was caused by a state actor.” Victoria W. v. Larpenter, 369 F.3d 475, 482 (5th Cir.
2004) (citing Bush v. Viterna, 795 F.2d 1203, 1209 (5th Cir. 1986)). Lillie must also show
that the constitutional or statutory deprivation she suffered was intentional or due to
deliberate indifference and not the result of mere negligence. See Gobert v. Caldwell, 463
F.3d 339 (5th Cir. 2006).
IV. 	ANALYSIS
The Court finds that no genuine issue of material fact exists as to Lillie’s claims
against the City under section 1983. Generally, “[m]unicipal liability under section 1983
requires proof of three elements: a policymaker; an official policy; and a violation of
constitutional rights whose ‘moving force’ is the policy or custom.” Piotrowski v. City of
Houston, 237 F.3d 567, 578 (5th Cir. 2001) (quoting Monell v. Dep’t. of Social Services,
436 U.S. 658, 694 (1978)). Requiring satisfaction of each of these elements is “necessary
to distinguish individual violations perpetrated by local government employees from those
that can be fairly identified as actions of the government itself.” Id.
Lillie pursues her section 1983 claims under three theories of liability: the failure to
train, the failure to supervise, and the failure to adopt an appropriate policy regarding video
and audio recording. (Dkt. 66 at p. 4). Assuming, arguendo, that Lillie is able to
demonstrate a genuine issue as to all other elements of Monell liability, the Court finds that
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no genuine issue exists as to causation. Accordingly, the Court must grant summary
judgment on Lillie’s claims in the City’s favor.
To yield municipal liability under section 1983, an official policy must have been
the “moving force” behind the plaintiff’s constitutional violation. Piotrowski, 237 F. 3d at
580 (quoting Monell, 436 U.S. at 694). In other words, a plaintiff “must show direct
causation, i.e., that there was ‘a direct causal link’ between the policy and the violation.”
James v. Harris Cty., 577 F.3d 612, 617 (5th Cir. 2009) (quoting Piotrowski, 237 F.3d at
580). Ultimately, the direct causal connection between the policy and the alleged
constitutional deprivation “must be more than a mere ‘but for’ coupling between cause and
effect.” Johnson v. Deep E. Tex. Reg’l Narcotics Trafficking Task Force, 379 F.3d 293,
310 (5th Cir. 2004) (quoting Fraire v. City of Arlington, 957 F.2d 1268, 1281 (5th Cir.
1992)); see also City of Canton v. Harris, 489 U.S. 378, 391 (1989) (“must be closely
related to the ultimate injury” and have “actually caused” the constitutional violation
complained of).
Here, Lillie argues, “if an officer with minimal training and experience is left
completely 	to 	their 	own 	devices, 	with 	no 	supervision 	or 	policy-based 	form 	of
accountability, those intentional blind spots will inevitably lead to overreach, abuse,
oppression, and, in this case, criminal activity.” (Dkt. 66 at p. 7). This argument, of course,
is not particular to the alleged failures or harms in this matter and is insufficient to support
Monell liability.
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Lillie continues, “if Ruiz had a supervisor that checked in with him, and statutorily
acceptable and enforced protocols for using his body-worn microphone, he would never
have had the opportunity to commit these sexual assaults in the first place.” Id. This
argument sounds much like ‘but-for’ causation, which the Fifth Circuit has already
foreclosed in this context. See Johnson, 379 F.3d at 310.
These are Lillie’s only arguments on causation. See (Dkt. 66, 71). Lillie has not
presented any summary judgment evidence that would place at issue whether the City’s
alleged failure to require officers to use body-worn cameras is “affirmatively linked” to
Ruiz’s sexually assaulting Lillie. See Fraire, 957 F.2d at 1282. Neither is there any
evidence that the City’s alleged failure to train or supervise Ruiz “actually caused” Ruiz to
sexually assault Lillie. See Harris, 489 U.S. at 391. The Court finds that the relationship
between the City’s failures and Ruiz’s violation of Lillie’s constitutional rights is too
attenuated to create a fact question on Monell liability. 1
Ruiz acted heinously when abusing his position of power to criminally assault Lillie,
and the Court is highly sympathetic to the effects this incident has, and will continue to
have, on Lillie. Still, the law does not support imposing liability under section 1983 on the
City for Ruiz’s criminal conduct. Accordingly, there is no genuine issue as to Lillie’s
section 1983 claims against the City, and her claims must be dismissed.
1 Again, the Court is assuming arguendo that Lillie can create a fact issue as to the other Monell
elements. The Court refuses to and need not determine whether the alleged failures constitute an
official policy, whether Ruiz’s actions violated Lillie’s constitutional rights, or any other element
of Lillie’s Monell claim. It fails regardless.
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V. 	CONCLUSION
The Court GRANTS the City’s Motion for Summary Judgment (Dkt. 66). Lillie’s
claims against the City are DISMISSED with PREJUDICE.
SIGNED at Houston, Texas on March 16, 2026.
_______________________________
GEORGE C. HANKS, JR.
UNITED STATES DISTRICT JUDGE
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