1. Introduction

Lewis v. Delgado (5th Cir. Jan. 7, 2026) concerns a Fourth Amendment excessive-force claim arising from a “high-risk vehicle stop” conducted by Rosenberg, Texas police officers searching for a reported group of armed suspects. Officers stopped a vehicle matching a dispatch description (a white Dodge Charger with black rims and tinted windows). Unbeknownst to them, the occupants were an elderly couple: Michael Lewis and Regina Armstead.

Lewis had a dialysis-related stent in his left forearm. During the stop, officers handcuffed Lewis for approximately six minutes while they secured the scene and cleared the vehicle. Lewis later learned his stent was damaged and required surgical repair.

The central appellate issue was not whether force was used, but whether the district court correctly denied qualified immunity at summary judgment based on a purported factual dispute: when (if ever) the officers were on notice that handcuffing Lewis could injure his stent. The Fifth Circuit reversed, holding that the notice dispute was not material because—notice or not—Lewis failed to identify clearly established law making the officers’ conduct unconstitutional under these circumstances.

2. Summary of the Opinion

The Fifth Circuit reversed the denial of qualified immunity. It held that:

• Any dispute about whether officers had advance notice of Lewis’s medical condition was immaterial to qualified immunity because the right at issue was not clearly established on these facts.
• Lewis’s cited precedents—both within and outside the Fifth Circuit—were not sufficiently analogous in force, duration, context (routine stop versus high-risk armed-suspect stop), and indicators of pain/complaints to put officers on notice.
• Given the exigency of a high-risk stop, the brief duration of restraint (about six minutes total; about four minutes after scene security), and the absence of repeated complaints, no precedent “beyond debate” prohibited the officers’ conduct.
• Because the “clearly established” prong was dispositive, the court did not separately decide whether the officers’ conduct constituted excessive force under the Fourth Amendment.

3. Analysis

A. Precedents Cited

The opinion is driven by modern qualified-immunity methodology: strict attention to factual similarity when asking whether a right was clearly established. The Fifth Circuit organized its discussion around (i) procedural standards, (ii) qualified immunity doctrine, and (iii) the (non-)analogous excessive-force precedents offered by Lewis.

1) Summary judgment and reviewability of “material fact” determinations

• Solis v. Serrett and Hanks v. Rogers: cited for de novo review of a denial of qualified immunity at summary judgment. The panel uses these to frame the appellate posture: it may independently assess whether the legal prerequisites for qualified immunity are met.
• FED. R. CIV. P. 56(a): supplies the baseline summary judgment standard.
• Bailey v. Ramos (quoting Good v. Curtis): emphasizes that whether a dispute is “material” is itself a legal determination. This matters because the district court treated the notice dispute as material; the Fifth Circuit treats materiality as reviewable and rejects it.
• Perry v. VHS San Antonio Partners, LLC (quoting Anderson v. Liberty Lobby, Inc.): provides the definition of “material” fact—one that might affect the outcome. The court leverages this to conclude that the notice dispute cannot affect the outcome if qualified immunity turns on the absence of clearly established law regardless of notice.

2) Qualified immunity framework and the “clearly established” requirement

• Ashcroft v. al-Kidd: supplies the two-prong framework (constitutional violation + clearly established right).
• Melton v. Phillips (en banc): cited for the plaintiff’s burden to establish both prongs. This supports the panel’s insistence that Lewis must produce precedent putting the point “beyond debate.”
• Pearson v. Callahan: authorizes courts to decide prongs in either order and to resolve on clearly-established grounds alone. The Fifth Circuit uses Pearson explicitly to “begin and end” with clearly established law, avoiding a merits ruling on excessive force.
• Morrow v. Meachum (quoting al-Kidd): reiterates the “beyond debate” standard for clearly established law.
• D.C. v. Wesby: identifies sources of clearly established law as controlling authority or a “robust consensus of cases of persuasive authority,” and (in a footnote) notes uncertainty about when lower-court cases suffice. The panel invokes Wesby to reject reliance on a thin or mixed collection of out-of-circuit decisions.
• Mullenix v. Luna (quoting al-Kidd): forbids defining clearly established law at a high level of generality. This is the doctrinal anchor for rejecting Lewis’s attempt to rely on general “minimal force on compliant suspects” propositions.
• Rogers v. Hall (quoting Plumhoff v. Rickard): emphasizes that the contours of the right must be sufficiently definite for any reasonable officer to understand the conduct is unlawful. The Fifth Circuit uses this to justify requiring close factual analogies in handcuffing/medical vulnerability contexts.

3) Fifth Circuit excessive-force precedents: distinguished as factually inapposite

Lewis’s principal Fifth Circuit citations were treated as out-of-scale comparisons—either much more forceful, much longer, or in less exigent contexts.

• Deville v. Marcantel: involved a routine traffic stop with escalated, violent tactics (window broken, plaintiff pulled out, thrown against car, then tight cuffs), producing multiple injuries. The panel distinguishes Deville because the degree of force was far greater, the context lacked the high-risk armed-suspect exigency, and the conduct was more obviously gratuitous.
• Heitschmidt v. City of Houston: featured four-and-a-half hours in handcuffs and officers ignoring repeated complaints that cuffs were too tight, causing serious and permanent injury. The panel distinguishes Heitschmidt chiefly on duration, repeated ignored complaints, and the magnitude of restraint.
• Newman v. Guedry: baton strikes and repeated tasing during a traffic stop—far beyond mere handcuffing.
• Cooper v. Brown: prolonged K9 bite—again, qualitatively different from brief handcuffing.
• Bush v. Strain: alleged head shove into a window hard enough to break teeth after the plaintiff was already handcuffed—post-restraint punitive force.
• Ramirez v. Martinez: repeated tasing of someone who did not match the suspect description—another “severe force” comparator.

4) District court decisions cited by Lewis: rejected as insufficient to create clearly established law

• Ordonez v. Gonzalez and LeCompte v. Hendricks: treated as unpublished district court opinions that “fall far short” of a robust consensus. This reflects the Fifth Circuit’s reluctance to treat trial-level, nonbinding decisions as clearly establishing rights for qualified-immunity purposes.

5) Out-of-circuit handcuffing cases: acknowledged, but found non-consensus and factually stronger than Lewis’s circumstances

• Kopec v. Tate: ten minutes of handcuffing, suspect not a safety risk, repeated requests (at least four) for removal. The Fifth Circuit notes Kopec’s own caveat that the result might differ if officers were engaged in other imperative matters—precisely what the Fifth Circuit found here during a high-risk armed-suspect stop.
• Courtright v. City of Battle Creek: repeated complaints about handcuff pain.
• Herzog v. Winnetka: DUI suspect handcuffed for over an hour.
• C.B. v. City of Sonora: sixth grader handcuffed for over thirty minutes.
• Vondrak v. City of Las Cruces: handcuffed for over an hour and a half with multiple complaints.

The court’s comparative point is twofold: (i) Lewis was handcuffed for under six minutes; and (ii) Lewis did not repeatedly complain of cuff-related pain (the record showed only grunting/wincing). Accordingly, even if these cases suggest constitutional limits in more extreme settings, they do not form an “unambiguous” consensus condemning the officers’ specific conduct here—particularly in the high-risk stop context.

6) Out-of-circuit “duration” cases: used to show Lewis’s four-minute post-security restraint is minimal by comparison

• Martin v. Heidman (thirty-five minutes)
• Rabin v. Flynn (twenty-five minutes)
• Bastien v. Goddard (over four hours)
• Mglej v. Gardner (twenty minutes plus later re-cuffing during a ninety-five mile drive)
• Alexander v. County of Los Angeles (thirty-five minutes)

These cases function as a scaling argument: even assuming some “post-scene-security delay” can matter, the duration here is too short—relative to existing case law—to clearly establish unlawfulness.

B. Legal Reasoning

The reasoning proceeds in a tight sequence:

1. Identify the alleged factual dispute: whether officers had advance notice of Lewis’s dialysis-related vulnerability (from statements or visible discomfort).
2. Reframe the dispositive question: a factual dispute is “material” only if it can affect the legal outcome. Under qualified immunity, the outcome turns on whether clearly established law prohibited the conduct.
3. Assume notice arguendo: the panel effectively grants Lewis the factual assumption that officers knew of the condition before handcuffing, but holds it does not matter because the legal prohibition still is not clearly established. (The court also flags credibility/record problems with Lewis’s timeline and notes that merely saying someone is a dialysis patient does not necessarily communicate that handcuffing risks stent injury.)
4. Demand close analogy: applying Mullenix v. Luna and related Supreme Court guidance, the court rejects general excessive-force propositions and requires precedent that would clearly notify officers that brief handcuffing during a high-risk stop, even with alleged medical vulnerability, is unconstitutional.
5. Distinguish plaintiff’s cases on force, duration, context, and complaints: the cited Fifth Circuit and out-of-circuit cases involve more extreme force, longer restraint, less exigent conditions, and/or repeated ignored pain complaints.
6. Conclude no “beyond debate” rule exists: absent a controlling case or robust consensus on these facts, qualified immunity applies.
7. Avoid merits ruling: under Pearson v. Callahan, the court declines to decide whether the conduct was excessive force as an original constitutional matter.

The opinion thus reinforces a practical litigation reality in qualified immunity cases: plaintiffs must locate factually similar precedent not only on “handcuffing,” but on the specific combination of (i) brief duration, (ii) high-risk/armed-suspect stop exigency, (iii) minimal indicators of pain, and (iv) alleged medical susceptibility.

C. Impact

The decision’s likely effects are significant in Fourth Amendment/qualified-immunity litigation involving handcuffing:

• Notice of medical vulnerability may be legally irrelevant absent matching precedent: Even if officers are told of a condition (or observe mild discomfort), plaintiffs still must show clearly established law requiring officers to modify or avoid handcuffing under comparable exigency and time frames. The court treats the “notice” dispute as not outcome-determinative when precedent is missing.
• High-risk stop context narrows the pool of useful analogies: The opinion repeatedly contrasts routine traffic stops and post-restraint punitive force cases with high-risk armed-suspect scene control. Future plaintiffs will need precedents that account for heightened officer-safety concerns.
• Duration thresholds matter, especially in the clearly-established inquiry: By contrasting four-to-six minutes with cases involving twenty-five minutes to hours, the court signals that brief handcuffing (even after the immediate threat is resolved) will be difficult to litigate as “clearly established” excessive force unless there is compelling, closely aligned authority.
• Complaints and obvious distress remain pivotal facts: The opinion treats repeated complaints of tight cuffs as a core differentiator. Plaintiffs who can show repeated, explicit cuff-related complaints (and deliberate disregard) will still have stronger arguments under cases like Heitschmidt v. City of Houston, but Lewis limits the reach of those precedents to more extreme fact patterns.
• Merits stagnation risk: By resolving solely on clearly established law, the court contributes to the “Pearson” phenomenon: fewer appellate merits rulings that would clarify what the Constitution requires in new factual permutations (such as handcuffing a medically vulnerable person during high-risk stops). This can perpetuate the lack of precedent that the court cites as dispositive.

4. Complex Concepts Simplified

• Qualified immunity: a doctrine shielding officers from damages liability unless the plaintiff shows (1) a constitutional violation and (2) that the unlawfulness was clearly established at the time.
• Clearly established law: not a general statement like “don’t use excessive force,” but precedent that would make it obvious to any reasonable officer that the specific conduct in the specific context was unconstitutional.
• Summary judgment: a pretrial decision where the court can rule as a matter of law if there is no genuine dispute of material fact.
• Material fact: a disputed fact that could change the outcome under the governing law. Here, the Fifth Circuit held that when notice does not change the clearly-established analysis, the notice dispute is not “material.”
• High-risk vehicle stop: a stop executed with heightened safety procedures (commands, controlled exits, temporary handcuffing) because officers reasonably believe occupants may be armed or dangerous.
• Excessive force (Fourth Amendment): force that is objectively unreasonable under the circumstances. Importantly, this opinion does not decide whether the force was unreasonable; it decides only that prior case law did not clearly establish unreasonableness on these facts.

5. Conclusion

Lewis v. Delgado strengthens a fact-specific qualified-immunity barrier in handcuffing cases: when officers briefly handcuff a compliant person during a high-risk stop to secure a potentially armed-suspect scene, plaintiffs must point to closely analogous precedent—particularly regarding duration, complaints of pain, and the high-risk context—to overcome qualified immunity. The court held that alleged advance notice of a plaintiff’s medical vulnerability does not, by itself, make the unlawfulness “beyond debate” absent controlling authority or a robust, on-point consensus. As a result, factual disputes about notice may be deemed immaterial where the clearly-established prong fails regardless.