Mendoza v. Davis, No. 16-1807 (8th Cir. 2017)
Annotate this CaseRamon Mendoza, a naturalized United States citizen, challenged the district court's grant of summary judgment for ICE agent Justin Osterberg, the County, the County employees, and Sheriff Davis on numerous claims based on an improper immigration detainer that was issued and later withdrawn. The detainer was withdrawn once Osterberg confirmed that Mendoza was not in fact Ramon Mendoza-Gutierrez, an aggravated felon. The court concluded that Osterberg had arguable probable cause to issue the ICE detainer and was entitled to qualified immunity on plaintiff's Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics claim; the sheriff was entitled to qualified immunity because he had no direct participation in the alleged violations; there was no violation of Mendoza's constitutional rights and the County employees are entitled to qualified immunity; the district court properly granted summary judgment for Sheriff Davis and the County on plaintiff's claims of supervisory and municipal liability under 42 U.S.C. 1983 where employees received instructive memorandum and on-the-job training; the actions in this case cannot reasonably be attributed to a defective governmental policy or custom; even if there were no policies or training on how to handle ICE detainers, there was no constitutional violation; there was no Fifth Amendment due process violation; and there was no evidence of defendants' conspiracy in violation of section 1984(3). Accordingly, the court affirmed the judgment.
Court Description: Beam, Author, with Colloton and Gruender, Circuit Judges] Civil case - Civil rights. The agent issuing an ICE detainer had probable cause to do so based on the information provided by plaintiff and official files and other government records and he was entitled to qualified immunity on plaintiff's Bivens claim; the county sheriff had no direct participation in the alleged violations of plaintiff's civil rights and was entitled to qualified immunity; the county employees involved in plaintiff's detention reasonably believed plaintiff was another person based on the information provided to them and were entitled to qualified immunity; failure to train and supervise and municipal liability claims were properly rejected as the record showed employees received training and information regarding handling ICE detainers and followed the information and practices; any actions they took could not be attributed to a defective government practice or policy; none of defendants' actions meet the standard necessary for a substantive due process violation, and the conduct in question was, at most, negligent and did not rise to the level of a constitutional violation; civil conspiracy claim rejected as there was no constitutional violation in the case.
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