Macias v. Bexar County: Reinforcing Rule 16 Good Cause and Monell Liability Requirements

Introduction

Macias v. Bexar County is a Fifth Circuit decision issued on June 6, 2025. It arose from the December 2018 death of Fernando Macias—a mentally ill detainee—in the custody of Bexar County, Texas. Plaintiffs, the heirs and estate representatives of Macias, sued Bexar County and a medical provider under 42 U.S.C. § 1983 and the Americans with Disabilities Act (ADA). They alleged inadequate mental health treatment led Macias to refuse dialysis, resulting in his death.

The key issues on appeal were:

• Whether Bexar County could be held liable under § 1983 for conditions of confinement or for failure to train its officers (Monell liability).
• Whether the district court correctly granted summary judgment on the ADA claim.
• Whether the district court abused its discretion in denying plaintiffs leave to amend their complaint and in refusing to extend time for service of process on the correct medical‐provider entity.

The Fifth Circuit affirmed in all respects, emphasizing strict adherence to municipal‐liability standards under Monell and the “good cause” requirement of Federal Rule of Civil Procedure 16 for any post–scheduling‐order amendment or service extension.

Summary of the Judgment

The Fifth Circuit’s per curiam opinion resolved two principal sets of issues:

1. Summary Judgment on Merits
   • § 1983 Conditions-of-Confinement and Failure-to-Train Claims: The court held that plaintiffs failed both to show any constitutional violation and, independently, to produce evidence of a Bexar County policy or pattern (Monell requirement) that caused Macias’s harm.
   • ADA Claim: Plaintiffs did not dispute that Macias was a “qualified individual with a disability,” but the court affirmed summary judgment on the grounds that they failed to prove that Bexar County discriminated against him “by reason of” his disability—negating the second and third elements of an ADA Title II claim.
2. Denial of Leave to Amend and Service Extensions
   • The district court’s scheduling order deadline for motions to amend or for service extensions was missed by over one month. Under Rule 16(b)’s “good cause” standard, the court found no excuse for plaintiffs’ delay, denied leave to file a second amended complaint, and refused to extend time to serve the correct entity (“University Medical Associates”).
   • The Fifth Circuit reviewed these rulings for abuse of discretion and found none, noting plaintiffs never engaged with the Rule 16 good-cause factors.

Analysis

Precedents Cited

• Monell v. Department of Social Services (436 U.S. 658): Established that § 1983 municipal liability requires proof of a policy, regulation or longstanding practice—beyond isolated acts by employees.
• Ford v. Anderson County, Texas (102 F.4th 292): Reiterated that to hold a municipality liable under § 1983, a plaintiff must show a “persistent, widespread practice” amounting to a county policy or custom.
• Turner v. Baylor Richardson Medical Center (476 F.3d 337): Explains that “conclusory allegations, unsubstantiated assertions, or only a scintilla of evidence” cannot defeat summary judgment.
• Sanders-Burns v. City of Plano (594 F.3d 366): Clarified the interplay between Rules 15(a) and 16(b) regarding amendments after a scheduling order deadline.
• Shaw v. Restoration Hardware, Inc. (93 F.4th 284): Reviewed leave-to-amend denials under Rule 16(b)’s good-cause standard.

Legal Reasoning

The Fifth Circuit’s reasoning unfolded in two tracks:

1. Merits Review and Summary Judgment
   • Section 1983 Claims: Even viewing facts in the light most favorable to plaintiffs, no genuine dispute existed that Macias received constitutionally adequate medical care. Independently, no evidence proved Bexar County maintained an unconstitutional policy or practice causally connected to Macias’s death.
   • ADA Claim: The court accepted that Macias had a disability but found no evidence that Bexar County’s actions denied him services “by reason of” that disability.
   • Abandonment on Appeal: Plaintiffs’ appellate brief failed to address the district court’s alternative grounds (lack of municipal “pattern or practice,” failure to satisfy ADA elements two and three), resulting in waiver of those arguments.
2. Rule 16 Good Cause and Amendment/Service Rulings
   • The district court’s scheduling order set a deadline for amendments. Under Rule 16(b), that deadline can be modified only for “good cause.”
   • Plaintiffs moved for leave to amend and to serve a new party more than one month late, yet never addressed—or attempted to satisfy—the four Filgueira factors for good cause (explanation, importance, prejudice, availability of continuance).
   • Accordingly, the district court properly exercised its discretion to deny the untimely motion and to strike the improperly filed second amended complaint.

Impact

Macias v. Bexar County reinforces two significant principles in federal civil practice and constitutional tort law:

• Municipal Liability Under § 1983 — Courts will demand concrete proof of an official policy or persistent practice (Monell) when adjudicating claims against counties or municipalities.
• Strict Enforcement of Scheduling Orders — Parties seeking to amend filings or extend service deadlines after a court‐imposed schedule must satisfy Rule 16(b)’s good‐cause test. Mere procedural confusion or oversight will not suffice.

Future litigants in the Fifth Circuit will see this case as a warning that both Monell proof and Rule 16 compliance are non-negotiable prerequisites to surviving summary judgment or seeking post‐deadline relief.

Complex Concepts Simplified

• Monell Liability — A claim under 42 U.S.C. § 1983 against a local government requires proof that the government’s own rule, policy, or widespread practice caused the constitutional violation, not just the actions of an individual employee.
• Qualified Immunity — Protects individual government officials from liability unless they violated “clearly established” rights. In this case, claims against individual jail officials were dismissed on qualified-immunity grounds in a prior interlocutory appeal.
• Summary Judgment — A pretrial ruling that no genuine dispute of material fact exists and that the moving party is entitled to judgment as a matter of law.
• Rule 16(b) “Good Cause” — Requires a party to show diligence and reasonable justification for missing a court‐ordered deadline before a court will permit an amendment or extension after that deadline.
• ADA Title II Elements — To prevail, a plaintiff must show (1) disability qualification, (2) denial of services by a public entity, and (3) discrimination “by reason of” the disability.

Conclusion

Macias v. Bexar County affirms the Fifth Circuit’s commitment to rigorous Monell liability standards and to upholding the finality of scheduling orders under Rule 16. By refusing both to entertain untimely amendments and to allow test-the-waters liability theories unsupported by evidence, the court has provided clear guidance:

• Municipal § 1983 plaintiffs must marshal evidence of official policy or an entrenched practice to survive summary judgment.
• Litigants seeking post‐deadline amendments or service enlargements must demonstrate good cause, including a diligent effort to meet court‐imposed deadlines.

This decision will shape both constitutional‐tort claims against governments and the management of procedural timelines in federal courts across the Fifth Circuit.