Unreported / Non-Citable
Background
Round Rock Police Officer Cody Johnston stopped Keaire Alvin Webb in February 2024 for an allegedly defective tail lamp and expired vehicle registration. After Webb declined to answer further questions and refused to sign a citation, officers removed him from his vehicle, handcuffed and searched him, impounded the vehicle, and took him to jail. Webb was charged with traffic violations and later received notices requiring payment of fines.
Webb sued Johnston and the City of Round Rock under 42 U.S.C. § 1983, alleging violations of the First, Fourth, Fifth, Ninth, and Fourteenth Amendments and adding a Monell claim against the city. After screening the in forma pauperis complaint under 28 U.S.C. § 1915(e), the district court dismissed it without prejudice under Heck v. Humphrey because Webb had not alleged that the underlying judgment had been invalidated. The court later denied Webb’s Rule 59(e) motion to alter or amend the judgment.
The Court’s Holding
The Fifth Circuit affirmed. Because Webb did not challenge the application of Heck in the district court, the panel reviewed his new arguments for plain error. It concluded that Webb was not entitled to relief because his pleadings effectively admitted that he had been found guilty of the traffic violations and fined, undermining his appellate argument that the record did not establish a conviction.
The court also held that Webb’s claims failed independently of Heck. It concluded that Johnston had reasonable grounds to stop Webb for traffic violations and arrest him for refusing to cooperate with law enforcement, making the arrest and search incident to arrest valid. The panel further held that the district court did not abuse its discretion by denying Rule 59(e) relief because Webb’s challenge to the sufficiency of the record could and should have been raised before judgment.
Key Takeaways
- A plaintiff who fails to contest the application of Heck in the district court may face plain-error review when raising that challenge for the first time on appeal.
- Webb’s allegations that a court ruled against him and continued to demand payment of fines supported the conclusion that the traffic charges had resulted in an adverse judgment.
- The Fifth Circuit found no constitutional violation because it deemed the traffic stop, arrest, and search incident to arrest valid, and it held that Rule 59(e) could not be used to present arguments that should have been made before judgment.
Why It Matters
The decision illustrates the procedural obstacles facing Section 1983 plaintiffs whose claims would undermine unresolved traffic convictions or similar judgments. It also emphasizes that factual and legal objections to a Heck dismissal should be presented before the district court enters judgment.
The opinion additionally shows that an appellate court may affirm dismissal on an independent merits ground when it concludes that the challenged stop, arrest, and search did not violate the Constitution.