Rivera v. County of Los Angeles, No. 11-57037 (9th Cir. 2014)
Annotate this CasePlaintiff filed suit against the Counties, alleging violations of the Fourth and Fourteenth Amendments, violation of the Bane Act, Cal. Civ. 52.1; and common law false imprisonment. Plaintiff was erroneously arrested pursuant to a 1985 warrant, released, and then erroneously arrested again pursuant to a 1989 warrant and detained for a month. Plaintiff shared the same first and last name as the true subject of the warrant and police mistakenly believed that plaintiff was that person both times he was arrested. The district court granted the Counties' motions for summary judgment on all claims and denied plaintiff's motion for reconsideration. The court concluded that the 1989 warrant satisfied the particularity requirement of the Fourth Amendment because it contained both the subject's name and a detailed physical description; that plaintiff was erroneously arrested based on the 1985 warrant simply did not affect whether the warrant itself satisfied the particularity requirement; and even if the Fourth Amendment did not require Los Angeles County to include more detailed information in the 1989 warrant in order to avoid the risk of repeated misidentification, defendant failed to show that the county had a policy or custom of failing to do so. The court also concluded that the officers' belief that plaintiff was the true subject of the warrant was not unreasonable under the Fourth Amendment; plaintiff's detention did not violate the Due Process Clause of the Fourteenth Amendment; and, in regards to plaintiff's state law claims, because the employees relevant to this case would be able to invoke statutory immunities to avoid liability, the Counties could as well. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants.
Court Description: Civil Rights. The panel affirmed the district court’s summary judgment in an action in which plaintiff, Santiago Rivera, alleged multiple constitutional and state law violations arising out of his mistaken arrest and month-long detention based on a 1989 warrant which had been issued for another person, also named Santiago Rivera. The panel rejected Rivera’s claim that Los Angeles County violated the Fourth Amendment by issuing the 1989 warrant without including a number corresponding to the true subject’s fingerprints. The panel held that the warrant satisfied the particularity requirement because it contained both the subject’s name and a detailed physical description. The panel held that even if the Fourth Amendment did require Los Angeles County to include more detailed information in the 1989 warrant, Rivera failed to show that the County had a policy or custom of failing to do so. The panel held that San Bernardino sheriff’s deputies were not unreasonable in believing that Rivera was the subject of the warrant at the time of arrest given that the name and date of birth on the warrant matched Rivera’s and the height and weight descriptors associated with the warrant were within one inch and ten pounds of Rivera’s true size. The panel held that Rivera’s detention did not violate the Due Process Clause of the Fourteenth Amendment. The panel determined that Rivera had not presented any evidence that either Los Angeles County or San Bernardino County knew that Rivera was not the true subject of the warrant. Nor did the circumstances of this case suggest that further investigation into Rivera’s identity was required, especially given that he had been provided procedural protections and court access. Finally, the panel affirmed the district court’s dismissal of Rivera’s state law claims on the basis of state law statutory immunities. Concurring in part and dissenting in part, Judge Paez stated that although he agreed with the majority that Rivera’s Fourth Amendment claims against Los Angeles County and San Bernardino County, his Fourteenth Amendment claims against San Bernardino County, and his state law claims against both counties must fail, he disagreed with the majority’s analysis of the due process claim in this case. In Judge Paez’s view, Rivera raised a genuine issue of material fact as to whether Los Angeles County deprived him of liberty without due process of law by failing to investigate his claims of innocence.
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