Archangel v. City of Houston

Opinion

□ Southern District of Texas ENTERED September 25, 2025 UNITED STATES DISTRICT COURT Nathan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

JEFFREY C ARCHANGEL, § § Plaintiff, § § VS, § CIVIL ACTION NO, 4:24-CV-03436 § CITY OF HOUSTON, ef al., § § Defendants. § ORDER Before the Court are United States Magistrate Judge Peter Bray’s Memorandum and Recommendation filed on August 29, 2025 (Doc. #33), Plaintiff Jeffrey Archangel’s Objections (Doc. #34), and Defendants City of Houston (“Houston”), David Crowder (“Crowder”), and Alexander Vinogradov’s (“Vinogradov”) Response (Doc. #35), The Magistrate Judge’s findings and conclusions are reviewed de novo. FED. R. CIv. P. 72(b); 28 U.S.C.§ 636(b)(1); United States v. Wilson, 864 F.2d 1219, 1221 (Sth Cir. 1989). Having reviewed the parties’ arguments and the applicable legal authority, the Court adopts the Memorandum and Recommendation as its Order. In this case, Plaintiff alleges Crowder and Vinogradov—detectives with the Houston Police Department—falsely arrested him for robbery and murder. Plaintiff asserts Fourth Amendment claims against Crowder and Vinogradov, as well as two Monell claims against Houston. Doc. #18. All Defendants moved to dismiss Plaintiffs claims against them, Doc, #25 and Doc. #26. The Magistrate Judge recommended this Court grant Defendants’ motions to dismiss. Doc. #33. Plaintiff objects to the Memorandum and Recommendation, arguing the Magistrate Judge in finding “there was no Fourth Amendment violation, and [Crowder and Vinogradov] are

entitled to qualified immunity.” fd. at 17. Specifically, in his Memorandum and Recommendation, the Magistrate Judge concluded Plaintiff “has not alleged facts permitting an inference that [Crowder and Vinogradov] lacked arguable probable cause” to arrest Plaintiff. fd; Club Retro, LLC, y, Hilton, 568 F.3d 181, 207 (Sth Cir, 2009), However, the Court agrees with the Magistrate Judge that “[e]ven if mistakes were made” in the investigation leading to Plaintiffs arrest, “there is no evidence that any mistake led to a constitutional violation.” Doc. #33 at 17; see Williams y. City of Amory, Mississippi, 254 F. App’x 334, 335 (Sth Cir. 2007) (holding that negligent police conduct is insufficient to overcome qualified immunity in a Fourth Amendment case). As such, Plaintiff's objections to the Memorandum and Recommendation are overruled. Accordingly, Defendant Houston’s Motion to Dismiss (Doc. #25) and Defendants Crowder and Vinogradov’s Motion to Dismiss (Doc. #26) are GRANTED. Plaintiff's claims are hereby DISMISSED WITH PREJUDICE. It is so ORDERED. SEP 2.5 2025 Date The Honorable Alfied H. Bennett United States District Judge