Williams v. Town of Clinton

Case: 26-30139 Document: 54-1 Page: 1 Date Filed: 08/17/2026

United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit ____________ FILED August 17, 2026 No. 26-30139 Lyle W. Cayce Summary Calendar Clerk ____________ Maurice Williams, Plaintiff—Appellant, versus Town of Clinton; Charles Brown, Individually, Defendants—Appellees. ______________________________ Appeal from the United States District Court for the Middle District of Louisiana USDC No. 3:23-CV-119 ______________________________ Before Haynes, Graves, and Ramirez, Circuit Judges.

Per Curiam:* Following his arrest by a Town of Clinton, Louisiana (the “Town”), police officer, Maurice Williams filed federal and state claims against the Town and the officer. The district court dismissed all claims. As explained below, we AFFIRM.

Case: 26-30139 Document: 54-1 Page: 2 Date Filed: 08/17/2026

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I. Background In October 2021, Officer Charles Brown of the Town’s police department issued Williams a misdemeanor summons under the Town’s “dogs not to run at large” ordinance, with a court date of December 7, 2021.

Though Williams did not attend because he claims he was unable to appear in response to this summons because the court was not in session on that day, a warrant was issued for Williams’s arrest for failure to appear.

On February 28, 2022, the district attorney contacted Williams to inform him of the warrant. On the morning of March 2, Officer Brown went to Williams’s residence to execute the warrant and arrest Williams. Williams alleges that the following occurred during execution of the arrest: Officer Brown needlessly pepper[-]sprayed Williams, beat Williams, and caused serious bodily harm to Williams’[s] neck.

Officer Brown grabbed [Williams’s] left hand and shoved it in between his shoulder blades, slammed his face into a door, injuring his head, all while [Williams] was barefoot and with a cast on one arm. [Williams] did not resist arrest, and at age 70, would be no threat to an officer.

In February 2023, Williams filed suit in federal court against the Town and Officer Brown in his individual capacity. After the district court dismissed various claims in the original complaint, Williams filed an amended complaint asserting claims under 42 U.S.C. § 1983 for false arrest, illegal seizure and excessive force,1 and malicious prosecution and, under state law, for battery, false arrest, defamation, and malicious prosecution.

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Defendants moved for summary judgment as to all claims, arguing that they were entitled to judgment as a matter of law for all claims and that Officer Brown was entitled to qualified immunity. The district court granted summary judgment on the federal and state false arrest claims, federal and state malicious prosecution claims, and state defamation claim. It denied summary judgment on the federal excessive force claim against the Town and on the state battery claim against both defendants, but it granted summary judgment on the federal excessive force claim against Officer Brown because it found he was entitled to qualified immunity such that this issue was not available against the Town. The district court declined to exercise supplemental jurisdiction over the remaining state law claims. The district court entered a final judgment disposing of all claims, and Williams promptly appealed.

II. Jurisdiction & Standard of Review The district court had jurisdiction over this case under 28 U.S.C. §§ 1331 and 1343 because Williams brought claims under 42 U.S.C. § 1983.

We have jurisdiction over this appeal under 28 U.S.C. § 1291 because the district court entered a final judgment.

“We review a district court’s grant of summary judgment de novo, applying the same standards as the district court.” Hagen v. Aetna Ins. Co., 808 F.3d 1022, 1026 (5th Cir. 2015). We also review de novo a district court’s determination of entitlement to qualified immunity. Trammell v. Fruge, 868 F.3d 332, 338 (5th Cir. 2017).

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III. Discussion On appeal, Williams argues that the district court erred in: (A) granting Officer Brown qualified immunity as to Williams’s § 1983 excessive force claim, and (B) granting summary judgment on Williams’s false arrest and malicious prosecution claims under federal and state law. We address each argument in turn.2 A. Qualified Immunity First, Williams argues that the district court erred in granting Officer Brown qualified immunity as to his § 1983 excessive force claim.3 We disagree.

Once a defendant pleads qualified immunity, the burden on summary judgment “then shifts to the plaintiff, who must rebut the defense by establishing a genuine fact issue as to whether the official’s allegedly wrongful conduct violated clearly established law.” Trammell, 868 F.3d at 338 (citation omitted). The two-part inquiry asks “first, whether taken in the light most favorable to the party asserting the injury, the facts alleged show the officer’s conduct violated a constitutional right; and second, whether the right was clearly established.” Id. at 339 (citation modified).

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The district court found that Williams did not meet his burden, as Williams’s “conclusory allegation that Brown acted with malice” was insufficient. We agree with the district court that Officer Brown is entitled to qualified immunity.

B. Summary Judgment Second, Williams argues that the district court erred in granting summary judgment regarding Williams’s false arrest and malicious prosecution claims. But again, we agree with the district court.

Summary judgment is proper “if 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.” Fed. R. Civ. P. 56(a).

We address summary judgment as to each claim in turn.

1. False arrest The district court denied Williams’s federal and state false arrest claims because “[Officer] Brown conducted the arrest pursuant to a facially valid bench warrant.” We agree. Under federal law, “[i]f there was probable cause for any of the charges made[,] then the arrest was supported by probable cause, and the claim for false arrest fails.” Deville v. Marcantel, 567 F.3d 156, 164 (5th Cir. 2009) (per curiam) (citation modified). Likewise, under Louisiana law, “[a] facially valid arrest warrant immunizes the officers from false arrest and imprisonment claims.” Id. at 172.

As such, summary judgment as to the false arrest claims was proper.

2. Malicious prosecution We also agree with the district court’s decision to grant summary judgment concerning Williams’s federal and state malicious prosecution claims.

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Because the elements of a § 1983 malicious prosecution claim and the elements of a Louisiana state malicious prosecution claim are “coextensive,” Armstrong v. Ashley, 60 F.4th 262, 279 (5th Cir. 2023) (citation omitted), we analyze them simultaneously. In this circuit, the plaintiff must show: (1) the commencement or continuance of an original criminal proceeding; (2) its legal causation by the present defendant against plaintiff who was defendant in the original proceeding; (3) its bona fide termination in favor of the present plaintiff; (4) the absence of probable cause for such proceeding; (5) malice; and (6) damages.

Espinal v. City of Hou., 96 F.4th 741, 748 (5th Cir. 2024).

Because, for the same reasons as above, we find that the arrest was supported by probable cause, Williams failed to show a genuine dispute of material fact as to the fourth element, and summary judgment was appropriate.

IV. Conclusion Accordingly, we AFFIRM.