Reported / Citable
Background
Salomon Campos, Jr. was prosecuted for capital murder following an investigation led by the Harlingen Police Department and the Texas Rangers. A Cameron County jury acquitted him of all charges on October 15, 2024.
Campos then sued the City of Harlingen, several law-enforcement officers, and three prosecutors in their personal capacities. He alleged illegal searches and seizures, destruction or manipulation of exculpatory evidence, denial of a fair trial, malicious prosecution, civil-rights conspiracy, failure to intervene, and municipal failures to train and supervise. The defendants moved to dismiss under Rule 12(b)(6), and the matter was referred to Magistrate Judge Karen Betancourt for pretrial proceedings.
The Court’s Holding
In a report and recommendation—not a final judgment—the magistrate judge recommended granting all three motions to dismiss and dismissing Campos’s complaint with prejudice. The court concluded that Campos repeatedly alleged falsification, fabrication, perjury, evidence tampering, and other misconduct without supplying facts identifying the particular statements, evidence, searches, seizures, agreements, or conduct supporting those conclusions.
Because the complaint did not plausibly allege an underlying constitutional violation, the court determined that the individual defendants were entitled to qualified immunity. It also concluded that Campos failed to plead a viable conspiracy or bystander-liability theory and failed to identify an official City policy, inadequate training program, pattern of similar violations, deliberately indifferent supervision, or facts satisfying the narrow single-incident exception to municipal liability. Although the federal malicious-prosecution claim was timely and the prosecution had ended favorably, Campos did not plausibly allege that it was instituted without probable cause or with malice. The court declined supplemental jurisdiction over any related Texas malicious-prosecution claim.
Key Takeaways
- An acquittal and prior detention satisfied favorable-termination and seizure components of a federal malicious-prosecution theory, but did not eliminate the need to plead facts showing an absence of probable cause and malice.
- General assertions that officers and prosecutors lied, fabricated evidence, or destroyed exculpatory material were insufficient without factual allegations identifying the challenged conduct and explaining its constitutional significance.
- The City could not be held liable merely because its employees allegedly committed misconduct; Campos needed facts connecting a constitutional injury to an official policy, custom, training deficiency, or deliberately indifferent failure to supervise.
Why It Matters
The recommendation illustrates the factual specificity required when civil-rights plaintiffs challenge an investigation and prosecution, particularly after defendants invoke qualified immunity. Courts need allegations tying each defendant to concrete misconduct, not collective accusations or labels.
It also underscores the demanding pleading requirements for municipal liability. Allegations arising from one investigation ordinarily do not establish a citywide policy, a pattern of violations, or the deliberate indifference necessary for failure-to-train or failure-to-supervise claims. The parties had 14 days to file specific objections before the assigned district judge considered whether to adopt the recommendation.