Lewis v. Delgado, 2026 WL 44682 (5th Cir. 2026)
Police in Rosenberg, Texas, received a report that several suspects in a white Dodge Charger had pointed a firearm at bystanders. Within minutes, an officer located a vehicle matching that description near the reported location. The officer initiated a stop and requested backup. Because the call involved multiple armed suspects, officers treated the encounter as a high-risk vehicle stop.
Consistent with department procedure, officers ordered the occupants to throw the keys out of the car, exit one at a time, approach slowly, and submit to handcuffing while the scene was secured. Body-camera footage recorded the encounter.
As it turned out, though, they’d pulled over the wrong white Charger. The vehicle was occupied by an elderly couple, Michael Lewis and Regina Armstead. Lewis had a dialysis-related stent implanted in his left forearm, and later claimed he told officers that placing handcuffs on that arm risked damaging the stent.
Lewis was handcuffed while officers cleared the scene and confirmed no other occupants or weapons were present. Including the time required to secure the vehicle, Lewis remained handcuffed for about six minutes. After the cuffs were removed, officers learned Lewis’s stent had been damaged, ultimately requiring surgery.
“Brief handcuffing during a high-risk stop does not become unconstitutional simply because an injury later occurs.”
Lewis sued, alleging excessive force under the Fourth Amendment. At summary judgment, the trial court denied qualified immunity, reasoning that a factual dispute existed over whether officers had notice of Lewis’s medical condition before or during the handcuffing.
The officers appealed, and the court of appeals reframed the issue. The question was not whether officers knew about Lewis’s stent. The question was whether — with or without that knowledge — clearly established law prohibited briefly handcuffing a compliant subject during a high-risk stop while officers secured a potentially dangerous scene. If the answer was no, then the factual dispute about notice was immaterial.
Qualified immunity protects officers unless existing precedent places the constitutional question “beyond debate.” Courts are not permitted to define rights at a high level of generality. The inquiry must focus on whether prior cases with sufficiently similar facts clearly condemned the officers’ conduct.
Lewis relied primarily on prior handcuffing cases denying qualified immunity. The court found those cases unhelpful. In those decisions, officers applied substantially greater force or restraint — breaking windows, throwing suspects against vehicles, ignoring repeated complaints of pain, or leaving suspects in handcuffs for hours. None involved a high-risk stop for armed suspects. None involved handcuffing measured in minutes rather than hours. And none involved officers acting to quickly secure a scene believed to involve firearms.
Lewis was handcuffed for approximately six minutes. He did not verbally complain about the cuffs. Officers were actively searching for armed suspects during that time. Even assuming officers noticed brief signs of discomfort, no precedent clearly established that such conduct was unconstitutional. While the court acknowledged the seriousness of Lewis’s injury, qualified immunity does not turn on hindsight or medical outcomes. The question is whether the law clearly required officers to act differently at the time.
Lewis could not identify any controlling authority — or a robust consensus of persuasive authority — holding that officers violate the Fourth Amendment by briefly handcuffing a suspect during a high-risk stop, even where the suspect later turns out to have a medical condition making him more susceptible to injury. Absent such authority, officers lacked fair notice their conduct was unlawful.
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The case is not about whether the outcome was tragic. It was. It is about whether clearly established law put officers on notice that their conduct — handcuffing a compliant subject during a high-risk stop — was unlawful under the Fourth Amendment. Qualified immunity turns on notice, not injury. Serious injury alone does not defeat immunity.
Three elements of the court’s opinion provide helpful guidance to law enforcement officers and agencies:
- Context matters. High-risk stops involving reported firearms are evaluated differently from routine encounters. Courts account for the need to secure the scene quickly.
- Duration matters. Minutes in handcuffs are not treated the same as hours. Brief restraint while officers verify safety conditions is rarely condemned by courts.
- Medical vulnerability does not mean strict liability. Absent clearly established law requiring special handling in similar circumstances, officers are not constitutionally liable simply because a subject has an undisclosed medical condition.
The outcome of this case does not suggest officers should ignore medical information when it is known and actionable. But brief handcuffing during a high-risk stop does not become unconstitutional simply because an injury later occurs. Because no clearly established law prohibited the officers’ actions, they were entitled to qualified immunity.
The appellate court reversed the trial court’s denial of qualified immunity, ending the excessive force claim.
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