Unreported / Non-Citable
Background
Trelynn D’Maun Wormley died from a fentanyl overdose while detained in the Tarrant County jail. According to the complaint, he obtained the fentanyl from Aliyah Lyles, an employee of Keefe Commissary Network, L.L.C., the jail’s third-party commissary operator. Wormley’s mother and the mother of his minor child sued Tarrant County under 42 U.S.C. § 1983 and asserted state-law claims. They also sued Keefe Commissary Network and its parent, Keefe Group, alleging direct and vicarious liability, violations of the Texas Health and Safety Code, and gross negligence.
The district court granted the defendants’ Rule 12(b)(6) motions. It concluded that the plaintiffs had not plausibly alleged that Tarrant County maintained a de facto policy of allowing drugs into the jail and had not alleged facts showing that Keefe knew or should have known Lyles posed a foreseeable substantial risk of bringing drugs into the facility. The court dismissed the complaint with prejudice, except for one state-law claim dismissed without prejudice after the court declined supplemental jurisdiction.
The Court’s Holding
The Fifth Circuit affirmed. As to Tarrant County, the court held that the plaintiffs failed to plausibly allege an official custom or policy necessary for municipal liability under Monell. Their allegations did not establish a pattern of acts or omissions sufficiently extended or pervasive to demonstrate a de facto county policy of allowing drugs into the jail.
The court also held that the plaintiffs failed to state a negligent-supervision claim against Keefe. The complaint alleged no facts showing that Keefe knew or should have known of Lyles’s incompetence or potential to cause harm. Although the plaintiffs alleged that Lyles was connected to another jail overdose, they did not allege that Keefe knew of that connection. The district court also acted within its discretion by declining supplemental jurisdiction over the remaining state-law claim against the county after dismissing the federal claim.
Key Takeaways
- A detainee’s injury does not establish municipal liability under § 1983 without plausible allegations tying the injury to an official policy, custom, or sufficiently pervasive de facto practice.
- An alleged prior incident involving an employee does not support negligent-supervision liability unless the complaint plausibly alleges that the employer knew or should have known of the employee’s risk of causing harm.
- After dismissing the federal claims, the district court could decline supplemental jurisdiction over the remaining state-law claim.
Why It Matters
The decision underscores the factual specificity required at the pleading stage in jail-death cases. Allegations that contraband entered a facility, even with fatal consequences, must be connected to an identifiable municipal policy or pervasive practice to support a Monell claim.
It also reinforces that negligent-supervision claims under Texas law require facts supporting employer-level foreseeability. Allegations about an employee’s conduct alone are insufficient when the complaint does not plausibly show that the employer had actual or constructive knowledge of the danger.