Dusterhoft v. City of Austin

CourtDistrict Court, W.D. Texas
DecidedJuly 1, 2025
Docket1:24-cv-01479
StatusUnknown

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

Bluebook
Dusterhoft v. City of Austin, (W.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

JASON DUSTERHOFT, § § Plaintiff, § § v. § 1:24-CV-1479-RP § CITY OF AUSTIN, and TRAVIS COUNTY, § § Defendants. §

ORDER

Before the Court is Defendant Travis County’s Motion to Dismiss Plaintiff’s Complaint, (Dkt. 6), and Defendant the City of Austin’s Motion to Dismiss Plaintiff’s Complaint, (Dkt. 13). Plaintiff Jason Dusterhoft (“Dusterhoft”) has filed responses to both motions, (Dkts. 11, 24), and both Travis County and the City of Austin (“Defendants”) filed replies in support of their motions to dismiss, (Dkts. 12, 25). After considering the motions, the supporting evidence, and the relevant law, the Court finds that the motions should be granted. I. BACKGROUND Dusterhoft is a former City of Austin Police Officer who was terminated from the Austin Police Department (“APD”) in 2018. Dusterhoft v. City of Austin, No. 20-CV-1081-RP, 2023 WL 2697722, at *4 (W.D. Tex. Jan. 10, 2023), report and recommendation adopted, No. 1:20-CV-1081-RP, 2023 WL 2709704 (W.D. Tex. Mar. 29, 2023), aff’d, No. 23-50313, 2023 WL 6785842 (5th Cir. Oct. 13, 2023). Prior to this suit, which challenges Defendants’ refusal to rehire Dusterhoft (or, in Travis County’s case, refusal to hire him in the first place), Dusterhoft had filed another First Amendment retaliation claim in 2020 challenging APD’s decision to terminate him. Dusterhoft, 2023 WL 2697722. In that case, Dusterhoft alleged that in a meeting with APD Chief Brian Manley and Assistant City Manger Rey Arellano on July 14, 2017, after Manley informed Dusterhoft he was being demoted, Dusterhoft complained of “numerous criminal and serious policy violations being committed by Austin police officers and Chief Manley himself.” Id. at *1. Dusterhoft asserts that his subsequent demotion and later termination were retaliation for these “whistleblower” complaints. Id. Dusterhoft challenged the termination through arbitration but was unsuccessful. Id. This Court dismissed the complaint, id. at *4, and noted that“[w]hen public employees speak

pursuant to their official duties, they are not speaking as citizens and their speech is not constitutionally protected.” Id. at *3 (citing Garcetti v. Ceballos, 547 U.S. 410, 421 (2006)). Because “the content of Dusterhoft’s speech was primarily—if not entirely—information he learned through his role as an Assistant Chief,” it reflected “special knowledge gleaned from [his] position.” Id. (quoting Harrison v. Lilly, 854 F. App’x 554, 556 (5th Cir. Mar. 25, 2021)). Dusterhoft was therefore speaking as a public employee and not a private citizen. Id. The Court also concluded the speech did not concern a matter of public interest because the complaints “specifically reflected poorly on Chief Manley, who had just informed Dusterhoft that he was being demoted.” Id. at *4. Accordingly, Dusterhoft’s speech was not protected by the First Amendment. Id. The Fifth Circuit affirmed the decision. Dusterhoft v. City of Austin, No. 23-50313, 2023 WL 6785842, at *2 (5th Cir. Oct. 13, 2023). In the instant action, filed one year after the Fifth Circuit’s affirmance, Dusterhoft alleges that he has filed several complaints with the Office of Police Oversight and the DA’s office against

Chief Manley and other APD officials since his termination. (Compl., Dkt. 1, at 2–3). These complaints alleged, for example: misconduct by Chief Manley and Officer Lakes, involving injury to a child”; “tampering with evidence, interfering with an investigation, and an IA Non-Garrity complaint against City Management [City of Austin] personnel and APD officers”; and “failure to comply with a lawful subpoena.” (Id.). He also allegedly raised these complaints, which “would later implicate Travis County,” on a public livestream in the final week of his arbitration in 2019. (Id. at 6). He alleges the City of Austin and the Travis County District Attorney’s office colluded in refusing to investigate the complaints. (Id.). Dusterhoft also claims that Defendants have retaliated against him by refusing to hire him for positions for which he is allegedly qualified. (Id. at 3–4). According to Dusterhoft, the City of Austin “has had and continues to have a persistent, widespread practice of mistreating and retaliating against whistleblowers,” “constituting a de facto policy of retaliation.” (Id. at 11).

Travis County moved to dismiss on December 27, 2024, (Dkt. 6), and the City of Austin moved to dismiss on February 28, 2025, (Dkt. 13). II. LEGAL STANDARDS A. Rule 12(b)(6) Pursuant to Rule 12(b)(6), a court may dismiss a complaint for “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). In deciding a 12(b)(6) motion, a “court accepts ‘all well-pleaded facts as true, viewing them in the light most favorable to the plaintiff.’” In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (quoting Martin K. Eby Constr. Co. v. Dall. Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004)). “To survive a Rule 12(b)(6) motion to dismiss, a complaint ‘does not need detailed factual allegations,’ but must provide the plaintiff’s grounds for entitlement to relief—including factual allegations that when assumed to be true ‘raise a right to relief above the speculative level.’” Cuvillier v. Taylor, 503 F.3d 397, 401 (5th Cir. 2007) (citing Bell Atl.

Corp. v. Twombly, 550 U.S. 544, 555 (2007)). That is, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). A claim has facial plausibility “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. “The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A court ruling on a 12(b)(6) motion 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.” Dorsey v. Portfolio Equities, Inc., 540 F.3d 333, 338 (5th Cir. 2008) (citations and internal quotation marks omitted). A court may also consider documents that a defendant attaches to a motion to dismiss “if they are referred to in the plaintiff’s

complaint and are central to her claim.” Causey v. Sewell Cadillac-Chevrolet, Inc., 394 F.3d 285, 288 (5th Cir. 2004). But because the court reviews only the well-pleaded facts in the complaint, it may not consider new factual allegations made outside the complaint. Dorsey, 540 F.3d at 338. “[A] motion to dismiss under 12(b)(6) ‘is viewed with disfavor and is rarely granted.’” Turner v. Pleasant, 663 F.3d 770, 775 (5th Cir. 2011) (quoting Harrington v. State Farm Fire & Cas.

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