Garcia v. Cnty. of Riverside, No. 13-56857 (9th Cir. 2016)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983, the California Constitution, and state tort law, alleging that he was wrongfully incarcerated by LASD based on the misapplication of a felony warrant issued in 1994 for Mario L. Garcia, who has the same date of birth as plaintiff. On appeal, LASD, and former LA Sheriff Lee Baca challenged the district court’s denial of qualified immunity, absolute (quasi-judicial) immunity, and immunity under two California statutes. The court concluded that it has jurisdiction over defendants’ appeals from denial of state-law immunity because the district court’s denial determined rights collateral to those asserted in the action, and like the denial of qualified immunity, the district court’s decision is effectively unreviewable on appeal from a final judgment; LA County and LASD may only appeal denial of state-law statutory immunity; and Baca, in his individual capacity, may appeal denial of qualified immunity and of quasi-judicial immunity. The court also concluded that plaintiff has sufficiently pleaded a Fourteenth Amendment violation and he is not entitled to qualified immunity where, at the time of plaintiff's incarceration, the standards for determining whether alleged police conduct violates the Fourteenth Amendment were clearly established. In this case, although plaintiff’s arrest for driving under the influence was valid, the warrant on which he was later held matched only his first and last name and date of birth; plaintiff is nine inches taller and forty pounds heavier than the warrant subject; and, even a cursory comparison of plaintiff to the warrant subject should have led officers to question whether the person described in the warrant was plaintiff. Finally, because the facts plaintiff alleged go beyond the limits of quasi-judicial immunity, this immunity does not apply to Baca. Accordingly, the court affirmed the judgment.
Court Description: Civil Rights. The panel affirmed the district court’s denial of qualified immunity, absolute (quasi-judicial) immunity, and immunity under two California statutes in an action brought by Mario A. Garcia pursuant to 42 U.S.C. § 1983 and state law alleging that he was wrongfully incarcerated by the Los Angeles County Sheriff’s Department based on the misapplication of a felony warrant issued in 1994 for Mario L. Garcia, who has the same date of birth as plaintiff. The panel first held that former Los Angeles Sheriff Lee Baca in his individual capacity may appeal the denial of absolute quasi-judicial immunity for the same reasons he may appeal denial of qualified immunity in his individual capacity. The panel held that Los Angeles County and the Los Angeles Sheriff’s Department could not appeal denial of quasi-judicial immunity because they could not assert an absolute immunity in the first place. The panel held that it GARCIA V. CTY. OF RIVERSIDE 3 had jurisdiction over defendants’ appeals from denial of state- law immunity because the district court’s denial determined rights collateral to those asserted in the action, and like the denial of qualified immunity, the district court’s decision was effectively unreviewable on appeal from a final judgment. The panel held that plaintiff had sufficiently pleaded a Fourteenth Amendment violation arising from law enforcement’s failure to investigate his claim of mistaken identity after he was arrested. The panel stated that an obvious physical discrepancy between a warrant subject and a booked individual, such as a nine-inch difference in height, accompanied by a detainee’s complaints of misidentification, should prompt officers to engage in readily available and resource-efficient identity checks, such as a fingerprint comparison, to ensure that they are not detaining the wrong person. The panel further held that Sheriff Baca was not entitled to qualified immunity because at the time of plaintiff’s November 2012 incarceration, the standards for determining whether alleged police conduct violated the Fourteenth Amendment were clearly established. The panel held that Sheriff Baca was not entitled to absolute, quasi-judicial immunity because plaintiff challenged not just the fact of his incarceration but also the lack of procedures to prevent the misidentification. Finally, the panel rejected defendants’ contention that they were immune from plaintiff’s state-law claims because of immunities provided in California Penal Code § 847 and California Civil Code § 43.55. The panel held that those statutes do not shield defendants from liability under state law because plaintiff was not asserting claims “arising out of an[] arrest” or against the arresting officer. 4 GARCIA V. CTY. OF RIVERSIDE
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.