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Hatton v. Harris County Jail

United States District Court, S.D. Texas, Houston Division

April 25, 2019



          Lee H Rosenthal Chief United States District Judge

         Rachel Hatton sued the Harris County Jail, the Harris County Sheriff's Department, and Harris County, alleging that a guard assaulted her while she was incarcerated at the Harris County Jail in May 2016. Harris County removed to federal court. (Docket Entry No. 1). In July 2018, this court granted the Harris County Sheriff's Department's motion to dismiss the claims against it with prejudice. (Docket Entry Nos. 3, 5). The remaining defendants move for summary judgment. (Docket Entry No. 13). Although Hatton responded late and without asking for leave to file a late response, the court still considers her response in its analysis. (Docket Entry No. 15).

         Based on the pleadings; the motion and response; the record; and the applicable law, the court grants the defendants' motion for summary judgment. (Docket Entry No. 13). Final judgment is separately entered. The reasons are explained below.

         I. Background

         On May 6, 2016, Hatton was arrested and taken to the Harris County Jail. (Docket Entry No. 14-1 at 1). An inmate offense report filed the next day by Officer C. Busby states that around 1:45 a.m. on May 7, Hatton had a seizure while walking into a holding cell. (Docket Entry No. 14 at 1). The report states that Hatton struck “the holding cell door and then . . . the floor.” (Id.). Busby states that she went to the clinic to alert medical staff, who then took Hatton to the clinic for evaluation. (Id.). The report explains that Hatton was then transported to St. Joseph Hospital for further treatment. (Id.). Hatton received scalp sutures at the hospital and signed a waiver to leave the hospital against medical advice. (Docket Entry No. 14-1 at 16, 21-22). Hatton returned to the Harris County Jail, where she received a mental health evaluation and other medical care. (Id. at 26-27, 32, 34).

         Hatton alleges a different version of events in her complaint. She alleges that while she was going back to her cell on May 7, a female guard charged and punched her. (Docket Entry No. 1-2 at 5). Hatton alleges that she passed out from the attack, woke up in the jail's clinic, was given pills for her injuries, and was returned to her cell. (Id.). After she was released on bail, she discovered stitches in her head, cuts on her head and face, bruises on her body, and a black eye. (Id. at 6).

         Hatton claims that the defendants are liable for assault and battery and under 42 U.S.C. § 1983 for Officer Busby's alleged use of excessive force. (Id. at 6-7). She asserts that the defendants have waived sovereign immunity under the Texas Tort Claims Act. (Id.). The defendants, Harris County Jail and Harris County, move for summary judgment.

         II. The Summary Judgment Standard

         “Summary judgment is required when ‘the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.'” Trent v. Wade, 776 F.3d 368, 376 (5th Cir. 2015) (quoting Fed.R.Civ.P. 56(a)). “A genuine dispute of material fact exists when the ‘evidence is such that a reasonable jury could return a verdict for the nonmoving party.'” Nola Spice Designs, LLC v. Haydel Enters., Inc., 783 F.3d 527, 536 (5th Cir. 2015) (quoting Anderson v. Liberty Lobby, 477 U.S. 242, 248 (1986)). “The moving party ‘bears the initial responsibility of informing the district court of the basis for its motion, and identifying those portions of [the record] which it believes demonstrate the absence of a genuine issue of material fact.'” Id. (quoting EEOC v. LHC Grp., Inc., 773 F.3d 688, 694 (5th Cir. 2014)); see also Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986).

         “Where the non-movant bears the burden of proof at trial, the movant may merely point to the absence of evidence and thereby shift to the non-movant the burden of demonstrating by competent summary judgment proof that there is an issue of material fact warranting trial.” Id. (quotation marks omitted); see also Celotex, 477 U.S. at 325. Although the party moving for summary judgment must demonstrate the absence of a genuine issue of material fact, it does not need to negate the elements of the nonmovant's case. Boudreaux v. Swift Transp. Co., 402 F.3d 536, 540 (5th Cir. 2005). “A fact is ‘material' if its resolution in favor of one party might affect the outcome of the lawsuit under governing law.” Sossamon v. Lone Star State of Tex., 560 F.3d 316, 326 (5th Cir. 2009) (quotation omitted). “If the moving party fails to meet [its] initial burden, the motion [for summary judgment] must be denied, regardless of the nonmovant's response.” United States v. $92, 203.00 in U.S. Currency, 537 F.3d 504, 507 (5th Cir. 2008) (quoting Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (en banc)).

         “Once the moving party [meets its initial burden], the non-moving party must ‘go beyond the pleadings and by her own affidavits, or by the depositions, answers to interrogatories, and admissions on file, designate specific facts showing that there is a genuine issue for trial.'” Nola Spice, 783 F.3d at 536 (quoting LHC Grp., 773 F.3d at 694). The nonmovant must identify specific evidence in the record and articulate how that evidence supports that party's claim. Baranowski v. Hart, 486 F.3d 112, 119 (5th Cir. 2007). “This burden will not be satisfied by ‘some metaphysical doubt as to the material facts, by conclusory allegations, by unsubstantiated assertions, or by only a scintilla of evidence.'” Boudreaux, 402 F.3d at 540 (quoting Little, 37 F.3d at 1075). In deciding a summary judgment motion, the court draws all reasonable inferences in the light most favorable to the nonmoving party. Connors v. Graves, 538 F.3d 373, 376 (5th Cir. 2008); see also Nola Spice, 783 F.3d at 536.

         III. Analysis

         A. The Summary Judgment Evidence

         Harris County attaches to its summary judgment motion the following records from the Harris County Sheriff's Office:

• an inmate offense report dated May 7, 2016, describing the events leading up to and following Hatton's injuries; • records of Hatton's ...

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