Sosa v. Martin County, No. 20-12781 (11th Cir. 2021)Annotate this Case
Plaintiff filed a 42 U.S.C. 1983 action against the sheriff's department and deputies involved in plaintiff's second arrest based on mistaken identity. Plaintiff alleged that defendants violated his Fourth and Fourteenth Amendment rights by falsely arresting him, overdetaining him, and failing to institute policies and train deputies to prevent these things from happening.
The Eleventh Circuit affirmed the district court's rulings on the false arrest and Monell claims. The court concluded that the mistaken arrest of plaintiff on the wanted warrant of someone by the same name was reasonable within the bounds of the Fourth Amendment, and the deputies are entitled to qualified immunity on the false arrest claim. However, the court vacated the district court's dismissal of the overdetention claim because plaintiff sufficiently alleged facts establishing that defendants failed to take any action for three days and nights after they learned of information that raised significant doubts about defendant's identity. The court remanded for further proceedings.
The court issued a subsequent related opinion or order on January 4, 2022.
The court issued a subsequent related opinion or order on January 20, 2023.
The court issued a subsequent related opinion or order on February 6, 2023.