David Sosa v. Martin County, Florida, et al., No. 20-12781 (11th Cir. 2023)Annotate this Case
Deputy sheriffs arrested Plaintiff based on a warrant for another man of the same name, detained him, and released him when his identity was verified three days later. Plaintiff sued the deputies for violating his alleged due process right to be free from over-detention under 42 U.S.C. Section 1983. The district court dismissed Plaintiff’s complaint for failure to state a claim.
At issue was whether an individual detained for three days based on mistaken identity for a valid arrest warrant has stated a claim for relief under the Fourteenth Amendment for his over-detention. The Eleventh Circuit affirmed. The court reasoned that under Baker v. McCollan, no violation of due process occurs if a detainee’s arrest warrant is valid and his detention lasts an amount of time no more than three days. And both conditions are met here. The court explained that Plaintiff was arrested on a valid warrant and held for only three days. Thus, under Baker, Plaintiff’s complaint did not state a claim for a violation of his due process rights.
This opinion or order relates to an opinion or order originally issued on September 20, 2021.