Newman v. Smith County, Texas

District Court, E.D. Texas·Decided September 3, 2025·No. 6:24-cv-00144·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:24-cv-00144 Brian Newman et al., Plaintiffs, V. Smith County, Texas, et al., Defendants.

ORDER Plaintiffs brought this lawsuit under the Civil Rights Act of 1871 and Texas law after Torry Newman died while incarcerated in the Smith County jail. The case was referred to a magistrate judge. Defendants Larry Smith, John Shoemaker, Maria Vallejo-Ro- bles, Nicholas Lee Vega, Norali Velazquez, and Tre Kobe Wash- ington (collectively “Smith County defendants”) moved for sum- mary judgment based on qualified immunity. Plaintiffs opposed the motion but stated that they intend to dismiss defendants Larry Smith, John Shoemaker, and Tre Kobe Washington. Doc. 76 at 31. The magistrate judge issued a report and recommended that de- fendants Smith, Shoemaker, and Washington be dismissed. Doc. 85 at 28. The magistrate judge also recommended that the motion for summary judgment be granted as to the remaining Smith County defendants on plaintiffs’ claims against them arising un- der federal law. Jd. Plaintiffs timely objected. When timely objections to a magistrate judge’s report and rec- ommendation are filed, the court reviews de novo the parts of the report that have been properly objected to. Fed. R. Civ. P. 72(b)(3); 28 U.S.C. § 636(b)(1)(C). The court reviews unob- jected-to parts for clear error. Fed. R. Civ. P. 72(b), advisory com- mittee’s notes to 1983 addition; United States v. Wilson, 864 F.2d 1219, 1221 (Sth Cir. 1989) (per curiam).

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I. Plaintiff’s objections A. Objections 1 and 4 Plaintiffs contend that the report concludes that Newman was alive at 4:51 a.m. and thus wrongly resolves a credibility dispute. Doc. 88 at 2, 4. That is incorrect. The report acknowledges that plaintiffs dispute whether Washington saw Newman alive at 4:51 a.m. Doc. 85 at 15. The report then notes that Newman “may al- ready have been deceased at that time.” Id. It also acknowledges, however, that defendant believed that Newman was alive at 4:51 a.m. and that defendant lacked training to determine whether a person was in distress or having trouble breathing. Id. The magis- trate judge did not determine when Newman died, and plaintiffs have not shown how such a factual finding would alter the report’s findings or recommendations. Plaintiff’s first and fourth objec- tions are overruled. B. Objection 5 Plaintiffs also object that the report fails to consider material evidence that Newman was pleading for help due to an inability to breathe. Doc. 88 at 4–5. The report acknowledges that Newman yelled for help between 1:00 a.m. and 3:00 a.m. and complained that he could not breathe. Doc. 85 at 15. Even assuming that New- man was unable to breathe during that time, that fact does not es- tablish deliberate indifference. What matters is whether defend- ants were “aware of facts from which the inference could be drawn that a substantial risk of serious harm exists” and that they “also dr[ew] the inference.” Farmer v. Brennan, 511 U.S. 825, 837 (1994). The report’s qualified immunity analysis did not turn on whether Newman was unable to breathe when he was yelling for help. Plaintiffs have not shown why it should. The objection is overruled. C. Objections 2, 3, 6, and 7 Next, plaintiffs raise several objections to how the report char- acterizes the facts. Doc. 88 at 3–5. Plaintiffs also contend that the report misapplied or incorrectly relied on nearly all the cases it examined in its qualified-immunity analysis. Id. at 5–7. Plaintiffs’ specific objections are as follows: • The report erred in framing Newman’s yells for help as an unknown medical emergency when his yells that he could not breathe and needed both water and medicine were suf- ficient to create subjective awareness. These facts, plain- tiffs claim, are “very similar” to those in Ford v. Anderson County, 102 F.4th 292 (5th Cir. 2024). Doc. 88 at 3. • The report overemphasized that Newman was not on med- ical observation and the officers’ lack of knowledge of Newman’s asthma. In doing so, plaintiffs argue, the report required knowledge of a precise diagnosis to establish knowledge of a risk of harm. This, they further argue, clashes with Fifth Circuit caselaw that does not require knowledge of a diagnosis “where obvious signs and direct pleas establish a serious risk.” Id. at 4. • The report wrongly distinguished Ford and Austin v. John- son, 328 F.3d 204 (5th Cir 2003), because a jury could find that a known emergency existed and that defendants un- reasonably delayed in responding. Doc. 88 at 5. • The report incorrectly applied Carmona v. City of Browns- ville, 126 F.4th 1091 (5th Cir. 2025), by concluding that like the officers in Carmona, defendants here lacked subjective awareness. But, plaintiffs object, the facts stated in the re- port demonstrate obvious signs of an emergency. Doc. 88 at 5–6. • The report misapplied Taylor v. Riojas, 592 U.S. 7 (2020), because the need for medical attention here was so obvious that no on-point case is needed to inform a reasonable of- ficer of what action is required in such circumstances. Doc. 88 at 6. • The report treated knowledge of a diagnosis “as function- ally necessary” in conflict with Farmer v. Brennan, 511 U.S. 825 (1994), which permits an inference of knowledge from the existence of an obvious substantial risk. Doc. 88 at 6. • The report wrongly relied on cases where signs of a sub- stantial risk were ambiguous or not obvious because the facts here are “far closer to obvious-emergency scenar- ios.” Plaintiffs further contend that the facts are even more obvious than in Ford—which they characterize as denying qualified immunity even though a request for a doctor and to go to the hospital “left room for speculation.” Id. at 7. As an initial matter, plaintiffs largely assume in their objec- tions the conclusion they set out to prove. Plaintiffs assume that a substantial risk of serious harm was obvious when arguing that the report should have treated the risk as obvious. But plaintiffs never explain why the risk was obvious. They skip that step. That step matters. Plaintiffs do not engage with the report’s rationale for concluding that the risk in this case was not obvious. By failing to do so, plaintiffs ask this court to reject reasons to which they do not object—and which support the report’s find- ings and recommendations. That said, plaintiffs do challenge the report’s emphasis on the fact that Newman was not on medical observation and the offic- ers’ lack of knowledge of Newman’s asthma. They characterize that emphasis as creating a “diagnosis-specific knowledge” re- quirement. Id. at 6. But again, plaintiffs fail to address why the re- port emphasized those facts—namely, the report’s reliance on the reasoning in Ford. Doc. 85 at 18–19, 25. Nor do plaintiffs explain why the report’s reasoning about its emphasis on both facts sup- ports an inference that the report creates a new rule that conflicts with precedent. They just say that it does. Furthermore, plaintiff’s seventh objection does not accurately characterize Ford’s reasoning.

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Related

Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Michael Melton v. Hunt County
875 F.3d 256 (Fifth Circuit, 2017)
Taylor v. Riojas
592 U.S. 7 (Supreme Court, 2020)
Kelson v. Clark
1 F.4th 411 (Fifth Circuit, 2021)
Kokesh v. Curlee
14 F.4th 382 (Fifth Circuit, 2021)
Rogers v. Jarrett
63 F.4th 971 (Fifth Circuit, 2023)
Ford v. Anderson County
102 F.4th 292 (Fifth Circuit, 2024)
Carmona v. Olvera
126 F.4th 1091 (Fifth Circuit, 2025)