Tellez v. Harris County Texas

CourtDistrict Court, S.D. Texas
DecidedSeptember 4, 2025
Docket4:24-cv-04058
StatusUnknown

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

Bluebook
Tellez v. Harris County Texas, (S.D. Tex. 2025).

Opinion

Southern District of Texas ENTERED September 04, 2025 IN THE UNITED STATES DISTRICT COURT , Nathan Ochsner, Clerk FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION GABRIELLA TELLEZ, □ § § Plaintiff, § □ § Vv. § Civil Action No. H-24-4058 § HARRIS COUNTY TEXAS AND § . CHRISTOPHER ROGERS § . | § Defendants. § ORDER Pending before the Court are Defendant Harris County’s Motion to Dismiss

(Document No. 8); and Defendant Christopher Rogers’ Motion to Dismiss (Document No. 10). Having considered the Defendants’ motions, submissions, and applicable law, the Court determines that Defendant Harris County’s motion should be denied, and Defendant Christopher Rogers’ motion should be granted, ‘L_BACKGROUND This is a matter involving alleged violations of the United States Constitution. © Plaintiff Gabriella Tellez brings suit against Defendants Harris County and Christopher Rogers (“Rogers”) (collectively, “Defendants”. Plaintiff alleges that. Defendants deprived her of her Second and Fourth Amendment rights by detaining her, arresting her, seizing her property, charging her, and jailing her, “all without

warrant or reasonable suspicion or probable cause” during Plaintiff's employment

Mills Auto Storage, an impound lot used by law enforcement for impounded vehicles. ! On December 10, 2022, a nonparty to this matter, Alvin Riggins (“Riggins”), came to Mills Auto Storage to retrieve his car after being released from jail. Plaintiff. contends that Riggins was unable to show proof of ownership, and thus, Plaintiff denied Riggins entry to the lot causing him to become angry. Plaintiff further contends that Riggins pushed open the gate and begin approaching Plaintiff. At that point, Plaintiff deployed her personal firearm and pointed it at Riggins. Plaintiff alleges that Riggins turned away and walked out of the impound lot. Shortly thereafter, officers from the Harris County Sherrif’s Department arrived on the scene and Plaintiff was arrested for assault with a deadly weapon. Based on the foregoing, on October 22, 2024, Plaintiff filed suit in this Court asserting claims against the Defendants for “violations of the Fourth Amendment,” “violations of the Second Amendment,” and “municipal liability.”? On November 18, 2024, Harris County filed a motion to dismiss for failure to state a claim upon which relief can be granted. On November 25, 2024, Rogers filed a motion to dismiss for failure to state a claim upon which relief can be granted. On December 9, 2024,

! Plaintiff's Complaint, Document No. 1, § 9. ? Plaintiff's Complaint, Document No. 1 at 14-16.

Plaintiff responded to the Defendants’ pending motions to dismiss. On December 16, 2024, both Defendants replied in support of their motions to dismiss.

Il. STANDARD OF REVIEW Rule 12(b)(6) allows dismissal if a plaintiff fails “to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). Under Rule 8(a)(2), a pleading must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Although “the pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ .. . it demands more than . . . ‘labels and conclusions.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “[A] formulaic recitation of the elements of a cause of action will not do.” Jd. (quoting Twombly, 550 U.S. at 555). In deciding a Rule 12(b)(6) motion to dismiss for failure to state a claim, “[t]he ‘court accepts all well-pleaded facts as true, viewing them in the light most favorable to the plaintiff.’” In re Katrina Canal Breeches Litig., 495 F.3d 191, 205 (Sth Cir. 2007) (quoting Martin K. Eby Constr. Co. v. Dall. Area Rapid Transit, 369 F.3d 464, 467 (Sth Cir. 2004)). To survive the motion, a plaintiff must plead “enough facts to

state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “Conversely, ‘when the allegations in a complaint, however true, could not raise a claim of entitlement to relief, this basic deficiency should . . . be exposed at the point

of minimum expenditure of time and money by the parties and the court.’” Cuvillier

v. Taylor, 503 F.3d 397, 401 (Sth Cir. 2007) (quoting Twombly, 550 U.S. at 558). il. LAW & ANALYSIS Harris County and Rogers both move to dismiss Plaintiff's complaint, contending that the Plaintiff fails to state a claim upon which relief can be granted. The Court will consider, in turn, the merits of each pending motion before the Court. A, Defendant Harris County’s Motion to Dismiss Plaintiff's complaint alleges that Harris County is municipally liable for Rogers’ actions because they failed to properly train Rogers. Harris County moves

_ to dismiss Plaintiff's complaint, contending that Plaintiff fails to state a claim upon which relief can be granted. Harris County argues that they cannot be found liable if qualified immunity is found to apply to Rogers’ actions and that Plaintiffs allegations are conclusory. Plaintiff contends that the pleadings are sufficient to satisfy the applicable pleading requirements and survive a motion to dismiss. Under 42 U.S.C. § 1983, a municipality may be liable if execution of the government’s policy results in constitutional violations. See Monell v. Dept. of Soc. Servs., 436 U.S. 658, 694 (1978); see also 42 U.S.C. § 1983. To succeed on a claim for municipal liability, a plaintiff must prove “a policymaker; an official policy; and

a violation of constitutional rights whose ‘moving force’ is the policy of custom.” Piotrowski v. City of Houston, 237 F.3d 567, 578 (Sth Cir. 2001). However, the Fifth

Circuit has made clear that overcoming a motion to dismiss requires only that the plaintiff “plead facts that the challenged policy was promulgated or ratified by the city’s policymaker.” Gorden v. City of Dallas, 826 F.3d 280, 285 (Sth Cir. 2016). A plaintiff is not required to reference a specific municipal policy in their pleadings. id. Here, Harris County relies on Supreme Court precedent arguing that “[i]f the Deputies are not liable, then Defendant [Harris County] cannot be liable.” See City of Los Angeles v. Heller, 475. U.S. 796, 799 (1986) (holding that a jury’s conclusive finding that an officer did not violate a constitutional right necessarily precluded a finding that the city itself violated a constitutional right).* Harris County further alleges that Plaintiffs complaint should be dismissed because it makes conclusory allegations regarding training and supervision. In response, Plaintiff contends that she has plead sufficient facts to meet the pleading stage requirements. A thorough review of the record in this case reveals that Plaintiff has plead

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Tellez v. Harris County Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tellez-v-harris-county-texas-txsd-2025.