Errol Houston, Jr. v. New Orleans City

675 F.3d 441, 2012 WL 834099, 2012 U.S. App. LEXIS 5370
CourtCourt of Appeals for the Fifth Circuit
DecidedMarch 14, 2012
Docket11-30198
StatusPublished
Cited by9 cases

This text of 675 F.3d 441 (Errol Houston, Jr. v. New Orleans City) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Errol Houston, Jr. v. New Orleans City, 675 F.3d 441, 2012 WL 834099, 2012 U.S. App. LEXIS 5370 (5th Cir. 2012).

Opinions

RHESA HAWKINS BARKSDALE, Circuit Judge:

In this action under, inter alia, 42 U.S.C. § 1983, Errol Houston, Jr., claims defendants violated his Fourteenth Amendment rights (to keep and bear arms, incorporated from Second Amendment, and to due process) by retaining his lawfully-seized firearm after the district attorney refused charges. The action was dismissed under Federal Rule of Civil Procedure 12. AFFIRMED.

I.

As noted, dismissal was under Rule 12, as also discussed infra. Accordingly, the facts that follow are from the allegations in Houston’s complaint.

Houston was arrested by New Orleans police officers on 5 July 2008. Pursuant to that arrest, Houston’s firearm, a Glock 22 .40-caliber pistol, was seized. Approximately a month later, the district attorney entered nolle prosequi (abandonment of prosecution) on the charges against Houston.

Almost a year after his arrest, and following his requests for the return of his firearm being denied by the district attorney’s office and the police department, Houston filed this action on 2 July 2009, claiming, inter alia, violations of the right to keep and bear arms and of due process, and seeking primarily the return of his firearm. Houston alleged he had been informed that the new district attorney had implemented a policy of not returning firearms seized during arrests.

[444]*444Just over a month later, Houston again was arrested by New Orleans police officers. He was informed that a warrant for his arrest, on the charge of illegal possession of a firearm, had issued at the request of the new district attorney on 5 July, three days after this action was filed. That charge was also “nolle prossed”. In an amended complaint, Houston added claims for retaliation and unlawful arrest.

Regarding the district attorney, Houston’s right-to-keep-and-bear-arms and due-process claims were dismissed under Rule 12(b)(6) (failure to state claim). Subsequently, those claims against New Orleans and a former police superintendent were also dismissed, under Rule 12(c) (judgment on pleadings).

In so ruling regarding the Second Amendment and the district attorney, the district court concluded retention of the firearm was “reasonable ... because firearms are needed as evidence in instituting criminal prosecution” and, “[furthermore”, that “[Houston] does not have a Second Amendment right to the particular firearm seized”. Order and Reasons, at 7 (20 Sept. 2010). In its subsequent dismissal of that Second Amendment claim against New Orleans and the former police superintendent, the court further ruled: “law enforcement has a compelling interest in seizing weapons pursuant to a lawful arrest and as evidence of crimes”; and, “law enforcement narrowly tailors such seizures to those firearms involved in crimes and those firearms in possession of arrestees”. Order and Reasons, at 9 (10 Dec. 2010).

For the due-process claim, the court ruled the firearm’s retention did not violate due process because, inter alia: the firearm was “not a basic necessity of life”; defendants had an important interest in preserving evidence; and, Houston had not alleged he had exhausted state-law remedies, such as a contradictory motion (motion the non-moving party is likely, or should have the opportunity, to contest) for return of his firearm. Order and Reasons, at 9-10 (20 Sept. 2010); Order and Reasons, at 9 (10 Dec. 2010).

II.

In district court, following the dismissal of his Second Amendment and due-process claims, Houston dismissed voluntarily his retaliation and unlawful-arrest claims. At issue are only those concerning the Second Amendment and due process.

Although both district court decisions noted factual allegations contained not in the complaint, but in the parties’ memoranda for the motions, “matters outside the pleadings [were not] presented to ... the court”. Fed.R.Civ.P. 12(d). And, consistent with that, both decisions stated the issue as “whether [Houston] has alleged sufficient facts to show that Defendants deprived [him] of his constitutional rights”. (Emphasis added.) For these and other reasons, the decisions were Rule 12 dismissals, not Rule 56 summary judgments.

Rule 12(b)(6) and 12(c) dismissals are reviewed de novo. E.g., Jebaco, Inc. v. Harrah’s Operating Co., 587 F.3d 314, 318 (5th Cir.2009). All well-pleaded facts are accepted as true and viewed in the light most favorable to Houston. E.g., Randall D. Wolcott, M.D., P.A. v. Sebelius, 635 F.3d 757, 763 (5th Cir.2011). Viewing the facts, as pleaded, in that light, a motion to dismiss for failure to state a claim or for judgment on the pleadings should not be granted if the complaint provides “enough facts to state a claim to relief that is plausible on its face”. Jebaco, Inc., 587 F.3d at 318 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)).

[445]*445A.

The Second Amendment provides for “the right of the people to keep and bear Arms”. U.S. Const, amend. II. That right belongs to the individual, and “central” to it is the “core lawful purpose of self-defense”. District of Columbia v. Heller, 554 U.S. 570, 628-30, 128 S.Ct. 2783, 171 L.Ed.2d 637 (2008). The Amendment is “fully applicable to the States” through the Fourteenth Amendment because the right to keep and bear arms is “fundamental to our scheme of ordered liberty”. McDonald v. City of Chicago, — U.S. —, 130 S.Ct. 3020, 3026, 3036, 177 L.Ed.2d 894 (2010) (emphasis omitted).

Houston urges strict-scrutiny review of defendants’ alleged policy of retaining seized firearms. See, e.g., San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1, 16, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973) (“strict judicial scrutiny [has been found] appropriate in reviewing legislative judgments that interfere with fundamental constitutional rights”). Before reaching that level-of-review question, however, whether the Second Amendment encompasses the claimed right must be decided. Heller v. District of Columbia, No. 10-7036, 670 F.3d 1244, at 1251-52, 2011 WL 4551558, at *5 (D.C.Cir. 4 Oct. 2011); Ezell v. City of Chicago, 651 F.3d 684, 701-02 (7th Cir.2011); United States v. Chester, 628 F.3d 673, 680 (4th Cir.2010); United States v. Reese, 627 F.3d 792, 800-01 (10th Cir.2010); United States v. Marzzarella, 614 F.3d 85, 89 (3d Cir.2010). But see Nordyke v. King, 644 F.3d 776, 783 (9th Cir.2011) (“The Supreme Court’s reasoning in Heller and McDonald suggests that heightened scrutiny does not apply unless a regulation

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Eugene Frein v. Pennsylvania State Police
47 F.4th 247 (Third Circuit, 2022)
Mance v. Sessions
896 F.3d 390 (Fifth Circuit, 2018)
Silvester v. Becerra
Supreme Court, 2018
Clifford Tyler v. Hillsdale County Sheriff's Dep't
775 F.3d 308 (Sixth Circuit, 2014)
Errol Houston, Jr. v. New Orleans City
682 F.3d 361 (Fifth Circuit, 2012)
Nordyke v. King
664 F.3d 774 (Ninth Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
675 F.3d 441, 2012 WL 834099, 2012 U.S. App. LEXIS 5370, Counsel Stack Legal Research, https://law.counselstack.com/opinion/errol-houston-jr-v-new-orleans-city-ca5-2012.