Mendia v. Garcia, et al., No. 12-16220 (9th Cir. 2014)
Annotate this CasePlaintiff filed suit against two ICE agents, seeking damages for the time he spent in pre-trial detention on state criminal charges allegedly as a result of the agents' wrongful acts. The district court granted the government's motion to dismiss based on lack of standing. Plaintiff appealed, alleging that he needed the assistance of a bail bondsman to post the required bail and that he unsuccessfully tried to secure such assistance. The court concluded that plaintiff has adequately alleged that his inability to utilize the services of a bail bondsman caused him to remain in pre-trial detention unnecessarily, at least during the period in which the bail condition remained in effect. Plaintiff's complaint expressly alleged that every bail bondsman he contacted told him why: "because of the immigration detainer." Accordingly, the court reversed the judgment of the district court.
Court Description: Civil Rights. The panel reversed the district court’s dismissal, for lack of standing, and remanded in an action brought against two agents of the United States Immigration and Customs Enforcement seeking damages for the time plaintiff spent in pre-trial detention on state criminal charges allegedly as a result of the agents wrongfully lodging an immigration detainer against him even though he was United States citizen. The panel held that plaintiff adequately pled causation for Article III purposes because he sufficiently alleged that his inability to utilize the services of a bail bondsman caused him to remain in pre-trial detention unnecessarily, at least during the period in which the bail condition remained in effect. The panel determined that plaintiff plausibly alleged that the immigration detainer was at least a substantial factor motivating the bail bondsmen’s refusal to do business with him.
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