Jones v. Hamilton Cty. Sheriff, No. 16-3259 (6th Cir. 2016)Annotate this Case
Jones was arrested in 2013, charged with felonious assault. He pled guilty to a reduced charge on February 3, 2015. At his sentencing hearing that day, the judge imposed an 18-month sentence in the Ohio Department of Corrections, with 560-days credit for time served, but stated that Jones “may be supervised . . . if the parole board determines it is necessary.” The board would make that determination “[b]efore [Jones is] released,” and the sheriff’s office was to “process him.” The judge predicted that Jones “will never be transported.” The sheriff did not release Jones on February 3 or February 4. Jones’ counsel attempted to secure his release. Those efforts failed, absent documentation. The court finally filed the judgment on February 5, but the sheriff had processed Jones. He was transported on February 6. The Department applied the credit, gave Jones the official certificate of expiration of sentence, and released him that day. Jones sued the sheriff in his official capacity for damages, alleging violation of the Fourteenth Amendment and false imprisonment. The Sixth Circuit affirmed dismissal. Although Ohio generally treats its sheriffs as county policymakers, Ohio law required the sheriff to transport Jones to the Department. The sheriff, as an arm of the state in this respect, enjoys sovereign immunity from suit in federal court.