Case Explained: James Murray; Latavius Paschal; Antone Henderson Plaintiffs— v. James LeBlanc, Secretary of Department of Public Safety and Corrections; Seth Smith Defendants—

Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-07

The Fifth Circuit dismissed the interlocutory appeal filed by defendants James LeBlanc and Seth Smith regarding their claim of qualified immunity. The court held that while it lacked jurisdiction to review the district court’s determination that genuine factual disputes existed precluding summary judgment, it did have authority to review the purely legal question of whether the defendants’ conduct violated clearly established rights under the plaintiffs’ version of the facts. Applying the collateral order doctrine and binding precedent from *Crittindon v. LeBlanc*, 37 F.4th 177 (5th Cir. 2022), the court rejected the defendants’ argument that they lacked authority over pretrial detainees housed in parish jails containing Department of Public Safety and Corrections (DPSC) prisoners. The court reasoned that under the Basic Jail Guidelines and DPSC’s audit powers, state officials possess at least some control to ensure local facilities comply with constitutional standards, thereby negating the specific qualified immunity defense raised by the defendants on the legal issue alone. However, because the district court found unresolved factual disputes regarding the adequacy of supervision, classification systems, and the extent of DPSC involvement in the assaults, the appellate court could not proceed to a final ruling on liability at this stage. Consequently, the appeal was dismissed without prejudice, leaving the case to proceed in the district court where the factual issues must be resolved before any final judgment on qualified immunity can be made.

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