1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

CHRISTOPHER RUSANOWSKY, §

§

Plaintiff, §

§ 

v. § Civil Action No. 3:22-CV-1132

§

THE CITY OF DALLAS, SGT. ROGER §

A. RUDOLF, Individually and in §

his official capacity as a Dallas Police §

Department Police Officer, §

§

Defendants. §

______________________________________________________________________________

DEFENDANT SGT. ROGER A. RUDLOFF’S

MOTION

FOR SUMMARY JUDGMENT BASED ON QUALIFIED IMMUNITY

___________________________________________________________________________

TO THE HONORABLE COURT: 

Defendant Sgt. Roger A. Rudloff (“Sgt. Rudloff”) pursuant to Rule 56 of Civil Procedure

and Local Civil Rule LR 56.3, file this motion for summary judgment based upon qualified 

immunity as to all claims alleged against him by Plaintiff. Sgt. Rudloff separately files his

supporting brief and appendix in accordance with Local Civil Rules LR 56.5 and LR 56.6.

I. SUMMARY OF CLAIMS AND DEFENSES

Plaintiff asserts three claims against Sgt. Rudloff, pursuant to 42 U.S.C. § 1983, for alleged 

violations of his constitutional rights.

In this motion, Sgt. Rudloff seeks summary judgment on all claims against him. Sgt. 

Rudloff asserts the affirmative defense of qualified immunity in response to the 42 U.S.C. § 1983

claims against him. Per Local Civil Rule LR 56.3 (“Content of Motion”), the elements of each 

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claim or defense as to which he seeks summary judgment are set forth in his supporting brief. ECF 

No. 49.

IV. RELEVANT PROCEDURAL HISTORY

This case arises from Plaintiff’s arrest on May 30, 2022, On February May 23, 2022, 

Plaintiff filed his Original Complaint. ECF No. 1. This Court set deadlines for any summary 

judgment motions to be filed 30 days after Plaintiff received discovery responses from Sgt. Rudloff 

or from the date this Court denied discovery. ECF No. 34. On April 6, 2023, both Plaintiff and 

Sgt. Rudloff filed notices with the Court that they had complied with the Court’s discovery 

instructions. ECF Nos. 42-43. Thus, both Plaintiff and Sgt. Rudloff’s summary judgment motions 

then became due on May 8, 2023. 

This case is currently administratively closed. ECF No. 23.

V. SUMMARY OF UNDISPUTED FACTS

Pursuant to Local Rule LR 56.3(b), Sgt. Rudloff’s summary of undisputed facts is included 

in his supporting brief ECF No. 49.

VI. PRAYER FOR RELIEF

WHEREFORE, Defendant Sgt. Rudloff respectfully requests that the Court grant his

motion for summary judgment based on qualified immunity; dismiss with prejudice all of 

Plaintiff’s claims against him; enter judgment in his favor on all claims; and grant him all other 

relief that is consistent with this motion.

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 Respectfully submitted,

CITY ATTORNEY OF THE CITY OF DALLAS

Tammy L. Palomino

Interim City Attorney

/s/ J. Cheves Ligon

J. Cheves Ligon

Senior Assistant City Attorney

Texas State Bar No. 24070147

john.ligon@dallas.gov

7DN Dallas City Hall

1500 Marilla Street

Dallas, Texas 75201

Telephone: 214-670-3519

Facsimile: 214-670-0622

Attorneys for Defendants

CERTIFICATE OF SERVICE

I hereby certify that on May 8, 2023, I electronically filed the foregoing document with the 

clerk of court for the U.S. District Court, Northern District of Texas, using the CM/ECF system 

which will send notification to case participants registered for electronic notice. I further certify 

that to the extent applicable I have served all case participants not registered for electronic notice 

by another manner authorized by Federal Rule of Civil Procedure 5(b)(2).

s/ J. Cheves Ligon

Senior Assistant City Attorney

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