Biggers v. Massingill

CourtDistrict Court, N.D. Texas
DecidedJune 3, 2025
Docket4:23-cv-00359
StatusUnknown

This text of Biggers v. Massingill (Biggers v. Massingill) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Biggers v. Massingill, (N.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

STEVE BIGGERS,

Plaintiff,

v. No. 4:23-cv-00359-P

RON MASSINGILL,

Defendant.

MEMORANDUM OPINION & ORDER

Before the Court is Defendant Ron Massingill’s Motion to Dismiss (“Motion”). ECF No. 48. Having reviewed the Motion, applicable law, and related docket filings the Court will DENY the Motion. BACKGROUND This case arises out of Biggers’s series of appearances in the Hood County Commissioners’ Court. Based on a public comment rule enacted in 2021, the Hood County Commissioners’ Court allows public comment on agenda items at every meeting as well as items not on the agenda at the first scheduled meeting of each month. Biggers first made an appearance in the Hood County Commissioners’ Court on March 8, 2022, where he provided each commissioner a copy of the United States and Texas Constitutions. From March to November, Biggers attended several other hearings. According to the Amended Complaint, Massingill developed a “pattern of hostility” toward Biggers in those meetings. Allegedly, Massingill bantered and interrupted Biggers, singled Biggers out from the audience and criticized him, and even escorted Biggers out of one meeting. Then, in a December 13, 2022 meeting, Biggers took the podium to discuss and play a recorded conversation in which Massingill allegedly gloated about removing Biggers from prior meetings among other things. According to Biggers, Massingill spoke over Biggers and threatened to have him removed. Biggers returned in January and attempted to play the recording again but was removed by the deputy on Massingill’s orders. Biggers alleges that Massingill’s actions deprived him of rights protected by the United States Constitution including his rights to free speech and equal protection. The Motion contends that Massingill is entitled to absolute legislative and judicial immunity against all claims. Alternatively, the Motion argues that Biggers failed to adequately plead claims under the Equal Protection Clause and the Texas Constitution. The Court will address both arguments in turn. LEGAL STANDARD To survive a motion to dismiss under Rule 12(b)(6), a plaintiff must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible when the plaintiff pleads factual content that allows the court to reasonably infer that the defendant is liable for the alleged misconduct. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Unlike a “probability requirement,” the plausibility standard instead demands “more than a sheer possibility that a defendant has acted unlawfully.” Id. Where a complaint contains facts that are “‘merely consistent with’ a defendant’s liability, it ‘stops short of the line between possibility and plausibility of entitlement to relief.’” Id. (quoting Twombly, 550 U.S. at 557). When reviewing a Rule 12(b)(6) motion, the Court must accept all well-pleaded facts in the complaint as true and view them in the light most favorable to the plaintiff. Sonnier v. State Farm Mut. Auto Ins., 509 F.3d 673, 675 (5th Cir. 2007). However, the Court is not bound to accept legal conclusions as true. Iqbal, 556 U.S. at 678–79. To avoid dismissal, pleadings must show specific, well-pleaded facts rather than conclusory allegations. Guidry v. Bank of LaPlace, 954 F.2d 278, 281 (5th Cir. 1992). “When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Iqbal, 556 U.S. at 679. A court ruling on a motion to dismiss “may rely on the complaint, its proper attachments, documents incorporated into the complaint by reference, and matters of which a court may take judicial notice.” Randall D. Wolcott M.D., P.A. v. Sebelius, 635 F.3d 757, 763 (5th Cir. 2011) (citations and internal quotation marks omitted). ARGUMENT Massingill argues that each of Biggers’s claims is barred by legislative and judicial immunity. Massingill also argues that Biggers failed to adequately plead claims under the Equal Protection Clause and the Texas Constitution. A. Legislative Immunity & Judicial Immunity Massingill is not shielded by legislative or judicial immunity. The Supreme Court has held that “state and regional legislators are entitled to absolute immunity from liability under § 1983 for their legislative activities.” Bogan v. Scott-Harris, 523 U.S. 44, 49 (1998). That immunity “attaches to all actions taken ‘in the sphere of legitimate legislative activity.’” Id. at 54 (quoting Tenney v. Brandhove, 341 U.S. 367, 376 (1951)). And “[w]hether an act is legislative turns on the nature of the act, rather than on the motive or intent of the official performing it.” Id. Similarly, a judge is immune from suit for “acts committed within their judicial jurisdiction.” Imbler v. Pachtman, 424 U.S. 409, 418 (1976) (citation omitted). Actions that are functionally legislative are protected by legislative immunity. See Hughes v. Tarrant Cnty., Tex., 948 F.2d 918, 920 (5th Cir. 1991) (citation omitted). For example, in Bogan, a mayor prepared a budget proposal, and as a part of the package, called for the elimination of a city department. Bogan, 523 U.S. at 47. The city council ordinance committee approved the ordinance, eliminating the plaintiff’s administrative position, and the plaintiff filed a lawsuit arguing that the actions by the mayor and city council were retaliatory and therefore violated the First Amendment. Id. The Supreme Court found the act of voting for an ordinance was “quintessentially legislative,” and therefore the vice president of the city council was protected by legislative immunity. Bogan, 523 U.S. at 55. And even though the mayor was an executive official, the “introduction of a budget and signing into law an ordinance . . . were formally legislative.” Id. Likewise, in Empower Texans, Inc. v. Geren, the court found that a Texas House of Representatives Committee Chairman could deny media credentials to a news organization in a legislative session and be protected by legislative immunity. 388 F. Supp. 3d 738, 747 (W.D. Tex. 2019), rev’d on other grounds, 977 F.3d 367 (5th Cir. 2020). The Geren court reasoned that controlling access to the House floor allowed the House to “conduct[] its most characteristic legislative functions, e.g., debating and voting.” Id. at 746 (citation omitted) A Texas commissioners’ court judge wears many hats. Massingill carries the title of a “judge.” But he also operates as “county administrator handling ‘county business.’” Diaz v. Cantu, 123 F.4th 736, 746 (5th Cir. 2024) (citing Tex. Const. art. V, §§ 1, 18(b)) (emphasis added).

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Related

Sonnier v. State Farm Mutual Automobile Insurance
509 F.3d 673 (Fifth Circuit, 2007)
Tenney v. Brandhove
341 U.S. 367 (Supreme Court, 1951)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Bogan v. Scott-Harris
523 U.S. 44 (Supreme Court, 1998)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
RANDALL D. WOLCOTT, MD, PA v. Sebelius
635 F.3d 757 (Fifth Circuit, 2011)
Robert J. Guidry v. Bank of Laplace, Etc.
954 F.2d 278 (Fifth Circuit, 1992)
Empower Texans, Incorporated v. Charlie Ger
977 F.3d 367 (Fifth Circuit, 2020)
Empower Texans, Inc. v. Geren
388 F. Supp. 3d 738 (W.D. Texas, 2019)
Diaz v. Cantu
123 F.4th 736 (Fifth Circuit, 2024)

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Biggers v. Massingill, Counsel Stack Legal Research, https://law.counselstack.com/opinion/biggers-v-massingill-txnd-2025.