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Reyes v. Sazan

United States Court of Appeals for the Fifth Circuit
168 F.3d 158 (5th Cir. 1999)


Facts

Florentino and Elizabeth Martinez (plaintiffs) were driving from Texas to Alabama in a pickup truck owned by Ramiro Reyes (plaintiff). While they were driving through Louisiana, a state trooper named Carl Sazan (defendant) pulled the Martinezes over. The Martinezes had not been speeding, and a drug dog discovered no contraband. Despite this, Sazan made the Martinezes follow him to police headquarters for a complete search of the vehicle. Over $2,000 in damage was done to the truck in the course of the search, but no contraband was found and no charges were filed. The plaintiffs sued Sazan and his supervisors (defendants) in federal court, asserting federal and state claims for violations of their civil rights. Specifically, the plaintiffs claimed that the defendants had engaged in a conspiracy to target Hispanics and selectively enforce traffic laws against them. The defendants pleaded an affirmative defense of qualified immunity, but the plaintiffs asserted that the defendants could not claim such immunity in their individual capacities. The district court dismissed some of the claims, concluded that the conspiracy had been pled with particularity, and said it would grant summary judgment for the supervisors without evidence of some genuine issue of material fact in dispute. The defendants appealed.

Rule of Law

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Issue

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Holding and Reasoning (Higginbotham, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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