Myriam Parada v. Anoka County, No. 21-3082 (8th Cir. 2022)
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The Anoka County Jail referred every detainee born outside the United States, including Plaintiff, to Immigration and Customs Enforcement. The district court determined that this policy violates the Equal Protection Clause, and a jury awarded her $30,000 on a false-imprisonment theory.
The Eighth Circuit affirmed. The court explained that the district court’s conclusion was correct: Anoka County’s policy is a classic example of national-origin discrimination. On its face, it treats people differently depending on where they were born. Those born abroad must wait anywhere from 20 minutes to 6 hours longer while deputies consult ICE. For those born in the United States, by contrast, there is no call and release is immediate. The court explained that it is also significant that Anoka County had national-origin-neutral alternatives at its disposal. The failure to consider these alternatives provides further evidence that it did not adopt a narrowly tailored policy.
Court Description: [Stras, Author, with Grasz and Kobes, Circuit Judges] Civil case - Civil rights. The defendants' policy of referring every foreign-born arrestee to ICE and holding them until ICE responded was an example of national-origin discrimination and violated plaintiff's Equal Protection rights because every foreign-born person was required to wait 20 minutes to 6 hours for ICE while for those born in the U.S. there was no such call, and release was immediate; the policy was not specifically and narrowly framed to accomplish the County's interests, and the County had national-origin-neutral alternatives at its disposal; argument that plaintiff changed her theory of liability rejected; arguments that direct liability against a county for false imprisonment does not exist or does not exist on these facts was not raised on a timely basis; defendant failed to produce any evidence showing it was entitled to statutory immunity; attorney-fee award affirmed. [ November 29, 2022 ]
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