Background
Trelynn D’Maun Wormley died from a fentanyl overdose while detained in the Tarrant County jail. According to the complaint, Wormley obtained the fentanyl from Aliyah Lyles, an employee of Keefe Commissary Network, L.L.C., the jail’s third-party commissary operator. Lyles was not a party to the case or appeal.
Wormley’s mother and the mother of his minor child sued Tarrant County under 42 U.S.C. § 1983 and asserted state-law claims. They also sued Keefe Commissary Network and its parent, Keefe Group, alleging vicarious and direct liability, a violation of the Texas Health and Safety Code, and gross negligence. The district court granted the defendants’ Rule 12(b)(6) motions. It dismissed the claims with prejudice except for one state-law claim over which it declined supplemental jurisdiction and therefore dismissed without prejudice.
The Court’s Holding
The Fifth Circuit affirmed. It held that the plaintiffs did not plausibly allege municipal liability against Tarrant County because they failed to plead an explicit policy or a sufficiently extended or pervasive pattern showing a de facto county policy of allowing drugs into its jails. Because the federal claim was properly dismissed, the district court also acted within its authority in declining supplemental jurisdiction over the related state-law claims against the County.
The court also upheld dismissal of the negligent-supervision claim against Keefe. The complaint did not allege facts showing that Keefe knew or should have known that Lyles was incompetent or posed a foreseeable risk of bringing drugs into the jail. Although the plaintiffs alleged that Lyles was connected to another jail overdose, they did not allege that Keefe knew of that connection.
Key Takeaways
- A detainee’s injury does not, by itself, establish municipal liability under § 1983; the complaint must plausibly connect the injury to an official policy or a sufficiently pervasive de facto practice.
- A negligent-supervision claim under Texas law requires facts supporting foreseeability, including that the employer knew or should have known of the employee’s incompetence or potential to cause harm.
- After dismissing the federal claim, the district court permissibly declined to exercise supplemental jurisdiction over the related state-law claims against Tarrant County.
Why It Matters
The opinion underscores the factual specificity required at the pleading stage in jail-overdose cases. Allegations that contraband entered a jail through an employee must be tied to a county policy or pervasive practice to support municipal liability, and to an employer’s actual or constructive knowledge of a particular employee’s risk to support negligent supervision.