Case: 22-30218 Document: 00516713394 Page: 1 Date Filed: 04/14/2023 United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit FILED April 14, 2023 No. 22-30218 Lyle W. Cayce Clerk Manuel Adams, Jr., Plaintiff—Appellee, versus City of Harahan, Defendant—Appellant. Appeal from the United States District Court for the Eastern District of Louisiana USDC No. 2:20-CV-2794 Before Stewart, Dennis, and Southwick, Circuit Judges. Carl E. Stewart, Circuit Judge: This appeal arises from Manuel Adams’s suit against the City of Harahan (“the City”) for its alleged deprivation of his Fourteenth Amendment right to due process. Because the district court erroneously determined that Adams had a liberty interest in his career in law enforcement, we REVERSE the district court’s denial of the City’s Rule 12(c) motion and DISMISS Adams’s due process claim. Case: 22-30218 Document: 00516713394 Page: 2 Date Filed: 04/14/2023 No. 22-30218 I. Background A. Chief Walker’s Disciplinary Charges Against Adams Adams ascended the ranks to Captain over an eighteen-year career in law enforcement with the Harahan Police Department (“HPD”). He had an unblemished disciplinary record during his tenure with HPD. But that changed in October 2019, when HPD Chief of Police Robert Walker (“Chief Walker”) determined that Adams was guilty of numerous offenses, including: (1) Conduct Unbecoming an Officer; (2) Unsatisfactory Performance; and (3) False Statement. As a classified civil service employee, Adams was entitled to a fifteen-day appeal window of Chief Walker’s disciplinary determinations. See La. R. S. § 33:2561. Adams exercised his right to appeal a week after Chief Walker’s charges. However, Chief Walker emailed the Jefferson Parish District Attorney’s office (“JPDA”) to inform it of his disciplinary action against Adams before he exercised his right. After communicating with Chief Walker, JPDA placed Adams’s name on its witness notification list (the “Giglio list”).1 Adams alleges that an officer’s inclusion on the Giglio list is effectively a “death knell to a career in law enforcement.” Because the Giglio list is at JPDA’s discretion, a successful appeal by Adams would not force JPDA to remove his name from the list. Faced with no guaranteed way to get his name off of the Giglio list, Adams sued the City. 1 JPDA maintains a witness notification list in accordance with Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972). Those cases require JPDA to turn over any evidence favorable to the defendant. This includes evidence that the accused can use to impeach police officers that the prosecution relies on in building its case. Adams avers that his inclusion on the Giglio list labels him as a liar or bad cop, which operates as a bar to his continued career in law enforcement. 2 Case: 22-30218 Document: 00516713394 Page: 3 Date Filed: 04/14/2023 No. 22-30218 B. District Court Proceedings Adams brought a civil rights suit against the City for violation of his procedural due process rights, stigma-plus-infringement, and defamation under 42 U.S.C. § 1983. He included Louisiana state law claims for defamation, …
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