Reyes v. Sazan

Brief Fact Summary.

Sazan pled an affirmative defense of qualified immunity when the Martinez’s sued for civil rights violations after being wrongfully searched when driving a pickup truck owned by Reyes.

Synopsis of Rule of Law.

Under FRCP 7(a), a federal district court may require a plaintiff to plead a reply to an answer that contains an affirmative defense.

Facts.

The Martinez’s were driving a truck from Texas to Alabama owned by Reyes. En route to Alabama, a state trooper, Sazan, pulled the Martinez’s over. Sazan required the Martinez’s to follow him to police headquarters although the Martinez’s were not speeding and did not possess contraband. Sazan caused $2,000 worth of damage to the truck when he searched the vehicle, despite not charging the Martinez’s. Reyes sued Sazan in federal and state court for civil rights violations, and Sazan pled an affirmative defense of qualified immunity. The district court granted summary judgment to the plaintiffs.

Issue.

Whether a plaintiff is required to plead a reply to an answer that contains an affirmative defense?

Held.

Yes. The district court’s denial of qualified immunity is vacated, and the case is remanded to require the plaintiff’s to submit a reply to the qualified immunity defense. The district court erred in concluding that the plaintiff’s pleadings were particular. The district court, therefore, should have required the plaintiffs to reply to the affirmative defense and should have dismissed the case if the reply was insufficient.

Discussion.

FRCP 7(a) gives trial courts discretion in requiring a plaintiff to plead a reply when a government official has pled an affirmative defense of qualified immunity.