Gonzales v. City of Austin

District Court, W.D. Texas·Decided May 22, 2025·No. 1:22-cv-00655·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

ALEX GONZALES, SR., individually and as § “Next Friend” to minor child Z.A.G. and § ELIZABETH HERRERA, aka § ELIZABETH GONZALES, § individually and as “Next Friend” to § minor child Z.A.G., § § Plaintiffs, § § v. § 1:22-CV-655-RP § CITY OF AUSTIN, § § Defendants. §

JESSICA ARELLANO, individually, and as next § friend of Z.A., a minor child, wrongful death § beneficiary and heir to the Estate of Alex § Gonzales, Jr., § § Plaintiffs, § § v. § 1:23-CV-8-RP § THE CITY OF AUSTIN, GABRIEL § GUTIERREZ, and LUIS SERRATO, § § Defendants. §

ALEX GONZALES, SR., et al., § § Plaintiffs, § § v. § 1:23-CV-9-RP § LUIS SERRATO and § GABRIEL GUTIERREZ, § § Defendants. § ORDER Before the Court is Defendants City of Austin (the “City”) and Gabriel Gutierrez’ (“Gutierrez”) (collectively, “Defendants”) Rule 42(b) Motion for Bifurcated Trial. (Dkt. 339). Plaintiffs Alex Gonzales, Sr. and Elizabeth Herrera (collectively, the “Gonzales Plaintiffs”) filed a response in opposition, (Dkt. 343). Gutierrez replied, (Dkt. 356), but the City did not. Having reviewed the parties’ briefing, the record, and the relevant law, the Court finds that the motion

should be denied. I. BACKGROUND This is a Section 1983 case arising from two police officer involved shootings that took place in the early morning of January 5, 2021.1 The first shooting stemmed from an alleged road rage incident involving off-duty Austin Police Department (“APD”) Officer Gutierrez and civilians Alex Gonzales, Jr. (“Gonzales”) and Plaintiff Jessica Arellano (“Arellano”), which led to Gutierrez shooting and injuring Gonzales and Arellano. This shooting then led to a second confrontation which ended with on-duty APD Officer Luis Serrato (“Serrato”) fatally shooting Gonzales. The two shootings resulted in three lawsuits, which were consolidated into this action on August 2, 2023. (See Order, Dkt. 54). The Gonzales Plaintiffs assert claims under 42 U.S.C. § 1983 as wrongful death beneficiaries of Gonzales and heirs to the Estate of Gonzales. They allege that Gutierrez and Serrato used excessive force against Gonzales in violation of the Fourth Amendment.

(2d Am. Compl., Dkt. 85, ¶¶ 80–96). Arellano brings a Section 1983 claim against Gutierrez alleging that he used excessive force when he shot her, violating her Fourth Amendment rights. (Am. Compl., Dkt. 87, ¶¶ 139–147). The Gonzales Plaintiffs and Arellano also assert claims against the City pursuant to Monell v. Dept. of Social Services of City of New York, 436 U.S. 658 (1978). They allege

1 The facts of this consolidated action are more fully explained in the Court’s Order on the parties’ motions for summary judgment. (See Dkt. 328). that the City is liable for Arellano’s injuries and Gonzales’ death because the City’s official policies, practices, and customs were a cause of Gutierrez and Serrato’s uses of excessive force. (See id. ¶¶ 148–158; 3d Am. Compl., Dkt. 86, ¶¶ 138–162). On March 27, 2025, the Court issued its order on the parties’ motions for summary judgment. (Dkt. 328). The Court granted Serrato’s motion for summary judgment, finding that Serrato was entitled to qualified immunity on the Gonzales Plaintiffs’ Section 1983 claims against

him. The Court also granted in part and denied in part the City’s motions for summary judgment. The Court held that a reasonable jury could find that Gutierrez committed excessive force when he shot Gonzales and Arellano. On Plaintiffs’ Monell claims, the Court granted the City summary judgment on six theories of Monell liability but denied summary judgment on a seventh theory, holding that a reasonable jury could find that Gutierrez’ alleged excessive force was caused by an alleged City practice of permitting excessive force by under-investigating and under-disciplining it. (See id.). Subsequently, Arellano and Defendants reached a settlement of her claims, which has been approved by the Austin City Council. The City has represented that Arellano and Defendants anticipate filing a joint stipulation of dismissal shortly. (See Dkt. 345-6, at 4). Trial is currently set to begin on June 23, 2025. (Dkt. 330). The only claims remaining for trial are the Gonzales Plaintiffs’ excessive force claims against Gutierrez and their Monell claims against the City. On April 29, 2025,

Defendants filed the instant motion to bifurcate trial. (Dkt. 339). II. LEGAL STANDARD Rule 42(b) of the Federal Rules of Civil Procedure provides: “[f]or convenience, to avoid prejudice, or to expedite and economize, the court may order a separate trial of one or more separate issues….” Fed. R. Civ. P. 42(b); Nester v. Textron, Inc., 888 F.3d 151, 162 (5th Cir. 2018). “[T]here is an important limitation on ordering a separate trial of issues under Rule 42(b): the issue to be tried must be so distinct and separate from the others that a trial of it alone may be had without injustice.” McDaniel v. Anheuser–Busch, Inc., 987 F.2d 298, 305 (5th Cir. 1993). The Fifth Circuit has held that bifurcation is within the discretionary authority of the district court and is reviewed on an abuse of discretion basis. Nester, 888 F.3d at 162; First Tex. Sav. Ass’n v. Reliance Ins. Co., 950 F.2d 1171, 1174, n.2 (5th Cir. 1992).

III. DISCUSSION Defendants request that the Court bifurcate trial so that the Gonzales Plaintiffs’ excessive force claims are tried prior to the trial of their Monell claim. (Dkt. 339). They offer two justifications for their motion. First, they argue that bifurcation would promote judicial economy because if a jury finds that Gutierrez committed no constitutional violation, then the Court will avoid the need to try the Monell claim against the City. They argue that any concerns about inefficiency caused by the bifurcation can be solved by having the same jury try both claims. (Id. at 3–5). Second, Defendants argue that Gutierrez would be unduly prejudiced if the case was not bifurcated because the jury would hear evidence both as it pertains to the shootings in this case and other excessive force incidents by other APD officers that the Gonzales Plaintiffs allege support their Monell claim. Defendants contend that the jury may conflate the issues and be influenced by the actions of other officers in unrelated incidents when considering Gutierrez’ individual liability in this case. Defendants cite other court decisions that have allowed bifurcation in excessive force cases. (Id. at

5–10). In response, the Gonzales Plaintiffs argue that Defendants’ motion to bifurcate is untimely and Defendants have shown neither excusable neglect nor good cause for the Court to accept the untimely filing. (Resp., Dkt. 343, at 2–8). They also contend that bifurcation would not promote judicial economy and that any minimal prejudice to Gutierrez can be cured without bifurcation. (Id. at 8–11). In reply, Gutierrez explains that the idea for bifurcation only arose after Arellano settled her claims and the Court had narrowed the issues remaining for trial. He argues that the change in circumstances in this litigation is good cause for the Court to consider Defendants’ motion. (Dkt. 356).

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