Perdomo v. City of League City: Body-Camera Video May Defeat Pleadings and Support Qualified Immunity at Rule 12(b)(6) After a Split-Second Takedown

1. Introduction

Perdomo v. City of League City, Texas (5th Cir. Jan. 7, 2026) arises from a workplace dispute that escalated into a brief physical confrontation with police. Plaintiff-appellant Yoni Orli Perdomo, a subcontractor terminated mid-project, returned to a residential jobsite to retrieve tools and allegedly unpaid wages. After the general contractor demanded he leave and requested police removal, League City officers Trevor Rector and Tanner Surrat arrived.

The central factual dispute on appeal was whether Perdomo was “compliant/submissive” or “aggressive” immediately before Officer Rector tackled him. The decisive procedural issue was whether, at the Rule 12(b)(6) stage, the court could reject Perdomo’s version of events because body-camera video “blatantly contradicted” his allegations.

Perdomo asserted federal claims under 42 U.S.C. § 1983 (excessive force, false arrest/unreasonable seizure, deliberate indifference to medical needs) and related municipal-liability theories, plus state-law claims (including assault/battery framing, negligence theories, and malicious prosecution). The district court dismissed all claims; the Fifth Circuit affirmed.

2. Summary of the Opinion

The Fifth Circuit affirmed dismissal, holding that the body-camera video “blatantly contradict[ed]” Perdomo’s allegation that he made only “incidental contact” while “compliant.” The video instead showed Perdomo place his hands behind his back, turn, and slam his shoulder/back into Officer Rector’s chest twice, knocking the officer backward.

On those video-controlled facts, the court concluded:

No excessive force: Rector’s split-second tackle in response to Perdomo’s forceful contact (treated as felony assault) was objectively reasonable.
No false arrest/unreasonable seizure: probable cause existed based on the officers witnessing Perdomo’s conduct.
No deliberate indifference: officers called an ambulance almost immediately; allegations that moving Perdomo posed “obvious” risks were conclusory and did not plead actual awareness.
No Monell/ratification liability: absent an underlying constitutional violation, the City/Police Department could not be liable.
State-law immunity bars claims: Texas official immunity paralleled federal qualified immunity; governmental immunity also applied (including under Tex. Civ. Prac. & Rem. Code § 101.057 and the battery framing described in City of Watauga v. Gordon).

3. Analysis

A. Precedents Cited

1) Pleading standards and the role of video at Rule 12(b)(6)

White v. U.S. Corr., L.L.C.: supplied the de novo standard for reviewing Rule 12(b)(6) dismissals and the requirement to accept well-pleaded facts and reasonable inferences—unless displaced by controlling evidence.
Ashcroft v. Iqbal: anchored the plausibility requirement; conclusory characterizations (“compliant,” “submissive”) cannot replace factual content.
Heinze v. Tesco Corp. and In re Great Lakes Dredge & Dock Co.: reinforced that courts need not accept conclusory allegations or unwarranted inferences.
Harmon v. City of Arlington (quoting Scott v. Harris): provided the key doctrine that where video evidence “blatantly contradict[s]” the complaint, courts may reject the pleaded account.
- Scott v. Harris is the Supreme Court’s canonical statement that courts need not adopt a party’s version of facts that is “blatantly contradicted” by video such that no reasonable jury could believe it.

How they shaped the outcome: These authorities enabled the Fifth Circuit to treat the video as the factual baseline at the motion-to-dismiss stage, converting Perdomo’s “compliance” narrative into a nonstarter. Once the court adopted the video depiction, the remaining constitutional and state-law theories largely collapsed under objective-reasonableness and immunity doctrines.

2) Qualified immunity framework

Templeton v. Jarmillo (quoting Ashcroft v. al-Kidd): restated the two-prong test—(1) violation of a statutory/constitutional right and (2) clearly established law at the time.
Jackson v. City of Hearne: placed the burden on the plaintiff to overcome qualified immunity.
Pearson v. Callahan: permitted skipping the “clearly established” prong when no violation is plausibly alleged. The panel explicitly did so here.

How they shaped the outcome: The court resolved the case at prong one (no constitutional violation on the video facts), thereby avoiding the more contentious clearly-established-law inquiry.

3) Excessive force under the Fourth Amendment

Ontiveros v. City of Rosenberg (quoting Freeman v. Gore): supplied the Fifth Circuit’s excessive-force elements (injury; direct result of clearly excessive force; clearly unreasonable excessiveness).
Graham v. Connor: provided the governing objective-reasonableness factors—severity of crime, immediate threat, and active resistance.

How they shaped the outcome: Treating Perdomo’s conduct as felony assault and immediate threat, combined with the encounter’s five-second duration, made the Graham calculus strongly favor the officer.

4) False arrest / unreasonable seizure and probable cause

Glenn v. City of Tyler: restated that the Fourth Amendment permits arrests supported by probable cause.

How they shaped the outcome: Because the officers personally witnessed conduct the panel characterized as felony assault (or interference), probable cause existed and defeated the seizure-based claims.

5) Bystander liability

Whitley v. Hanna (quoting Randall v. Prince George's Cnty.): set the three-element test for an officer’s duty to intervene.

How they shaped the outcome: Without an underlying constitutional violation by Rector, Surrat had no duty to intervene under Whitley/Randall.

6) Deliberate indifference to medical needs

Austin v. City of Pasadena: articulated the deliberate-indifference standard in this context and emphasized the requirement of actual subjective awareness.
Domino v. Tex. Dep't of Crim. Just.: supplied the two-part awareness/inference formulation (knowledge of facts indicating substantial risk, and actual drawing of the inference).

How they shaped the outcome: Immediate ambulance-calling behavior, combined with the lack of pleaded facts showing officers actually perceived a substantial risk from moving Perdomo, defeated the claim.

7) Municipal liability (Monell) and ratification

Monell v. Department of Social Services: established that municipalities can be liable when an official policy/custom is the moving force behind a constitutional violation.
Young v. Bd. of Supervisors: recognized liability for endorsement/ratification of a constitutional violation.

How they shaped the outcome: The panel applied the foundational limitation: absent an underlying constitutional violation, Monell and ratification theories fail as a matter of law.

8) Malicious prosecution

Armstrong v. Ashley: cited for the requirement that prosecution be instituted without probable cause.

How they shaped the outcome: The probable-cause finding necessarily defeated malicious prosecution.

9) Texas immunities and tort framing

Hart v. O'Brien: equated Texas official immunity as “substantially the same” as federal qualified immunity (with a good-faith substitution).
Tex. Civ. Prac. & Rem. Code § 101.057: preserved governmental immunity for claims arising out of assault, battery, false imprisonment, and other intentional torts.
City of Watauga v. Gordon: held that excessive force claims in the context of a lawful arrest “arise out of battery,” not negligence, blocking attempts to plead around immunity through negligence labels.

How they shaped the outcome: Once the force was deemed objectively reasonable (and the officers acted in good faith), official immunity defeated individual state claims, while § 101.057 and Gordon defeated municipal exposure despite “negligence” pleading.

B. Legal Reasoning

1) Video-first fact selection at the pleading stage

The panel’s threshold move was methodological: it treated the body-camera footage as controlling where it “blatantly contradict[ed]” Perdomo’s narrative. This is not a trial-like weighing of competing evidence; rather, it is an application of the Scott/Harmon rule that the court is not required to credit allegations that cannot plausibly coexist with undisputed video content included in (or integral to) the pleadings.

Perdomo argued “ambiguity” due to a brief obstruction after contact. The court rejected that argument because the key dispute concerned the unobstructed moments before the tackle, which showed two forceful backward slams into the officer.

2) Objective reasonableness of the takedown (Graham applied to a five-second encounter)

With the video facts fixed, the court characterized Perdomo’s contact as felony assault and emphasized the speed of events (roughly five seconds). That brevity functioned as a reasonableness amplifier: it limited opportunities for de-escalation, alternative tactics, or additional warning. Under Graham v. Connor, the panel found:

Severity: the conduct was treated as a serious (felony) offense.
Threat: two forceful slams suggested an immediate safety risk.
Resistance/compliance: the video did not depict compliance; it depicted aggression.

On that framing, a tackle to subdue Perdomo was not “clearly excessive” or “clearly unreasonable” under Ontiveros v. City of Rosenberg.

3) Probable cause as a universal solvent for seizure-based claims

Having determined the officers witnessed conduct supporting felony assault (or interference), the panel concluded probable cause existed. Under Glenn v. City of Tyler, that probable cause justified arrest/seizure and thus defeated both false arrest and unreasonable seizure. The same probable cause finding also defeated malicious prosecution under Armstrong v. Ashley.

4) Medical-care claim rejected for failure to plead subjective awareness

The court treated the officers’ near-immediate ambulance call as inconsistent with deliberate indifference. Importantly, the opinion focuses on the awareness requirement: Perdomo alleged that moving him from sidewalk to grass risked aggravation, but he did not plead nonconclusory facts showing the officers actually recognized a substantial risk from that movement, as required by Austin v. City of Pasadena and Domino v. Tex. Dep't of Crim. Just..

5) No underlying violation, no Monell/ratification

The Monell and ratification discussions are doctrinally linear: municipal liability requires a constitutional wrong to be caused or endorsed. Because the panel found no constitutional violation, it held the City and Police Department could not be liable under Monell v. Department of Social Services or Young v. Bd. of Supervisors.

6) Texas tort claims blocked by official/governmental immunity and correct tort characterization

For individual officers, the panel applied Hart v. O'Brien to equate Texas official immunity with federal qualified immunity (substituting “good faith” for “clearly established”). Once the actions were deemed objectively reasonable and nothing suggested bad faith, official immunity attached.

For the City/Police Department, Tex. Civ. Prac. & Rem. Code § 101.057 preserved immunity for claims arising out of intentional torts. Perdomo attempted to plead negligence, but the panel relied on City of Watauga v. Gordon to characterize excessive-force-in-lawful-arrest claims as battery, not negligence—triggering § 101.057’s immunity retention.

C. Impact

Stronger early-stage dismissal leverage for defendants when video is in the record: The decision reinforces that, in the Fifth Circuit, body-camera footage can decisively narrow the factual universe at Rule 12(b)(6), enabling qualified immunity to be resolved without discovery when the plaintiff’s characterizations are contradicted by video.
“Split-second” context matters in Graham balancing: The opinion underscores how the temporal compression of events can justify decisive force where an officer is physically engaged and perceives threat. Plaintiffs may need to plead more precise, video-consistent facts (e.g., distance, timing, officer commands, alternative options actually available in the moment) to survive dismissal.
Probable cause findings can cascade across claims: By tying the same observed conduct to probable cause, the court simultaneously defeated false arrest, unreasonable seizure, and malicious prosecution theories.
Deliberate indifference remains difficult to plead absent concrete awareness facts: Immediate emergency response actions (calling an ambulance promptly) can be powerful counter-indicators, and conclusory “obvious risk” pleading is unlikely to suffice.
Texas pleading “negligence” will not avoid immunity where the gravamen is force: The reliance on City of Watauga v. Gordon signals continued skepticism toward negligence relabeling in excessive-force contexts.

4. Complex Concepts Simplified

Rule 12(b)(6) motion to dismiss: a procedural challenge arguing that, even if the complaint’s well-pleaded facts are true, the law does not permit relief. Here, the court treated the body-camera footage as overriding allegations that were incompatible with what the video showed.
“Blatantly contradicts” (Scott/Harmon): when an objective recording (like video) so clearly conflicts with a party’s factual story that no reasonable factfinder could accept the story, a court need not pretend the story is true for purposes of the motion.
Qualified immunity: protects officers from suit unless the plaintiff plausibly alleges a constitutional violation (and usually that the law was clearly established). The court ended the analysis at “no violation,” so it did not need to decide whether prior cases clearly established the unlawfulness.
Excessive force (Graham): judged from the perspective of a reasonable officer in the moment, not with hindsight; severity, threat, and resistance are key factors.
Probable cause: a reasonable basis to believe a crime was committed; if it exists, many seizure-related constitutional claims fail.
Deliberate indifference: more than negligence; it requires that officers actually recognized a substantial risk of serious harm and disregarded it.
Monell liability: cities are not automatically liable for employees; there must be an underlying constitutional violation tied to a policy/custom (or ratified wrongdoing).
Texas governmental immunity and § 101.057: Texas generally preserves immunity for intentional torts (assault/battery, etc.), limiting tort suits against governmental units. Courts may recharacterize “negligence” pleadings as battery when the substance is force during a lawful arrest.

5. Conclusion

Perdomo v. City of League City, Texas is a video-driven qualified-immunity affirmance that illustrates how swiftly a civil-rights complaint can be dismissed when body-camera footage contradicts the plaintiff’s characterizations of compliance and minimal contact. On the video facts—two forceful body slams followed by a rapid takedown—the Fifth Circuit found no excessive force, probable cause for seizure/arrest, no deliberate indifference, and therefore no municipal liability under Monell or ratification theories. The decision also reinforces Texas immunity doctrines, including the principle that “negligence” labels will not evade § 101.057 where the claim is substantively battery in the course of a lawful arrest.