Jackson v. Barnes, et al., No. 09-55763 (9th Cir. 2014)
Annotate this CasePlaintiff was convicted at his first trial of first degree murder in which the prosecutor relied on evidence obtained in violation of his Miranda rights, and after the conviction was reversed he was again convicted, this time without the use of the illegally obtained evidence. Plaintiff filed suit under 42 U.S.C. 1983 for damages as result of his conviction for first degree murder in violation of his Fifth Amendment rights. The court held that plaintiff's section 1983 claim against Sheriff Barnes for the Fifth Amendment violation was not barred by Heck v. Humphrey. Under Heck and Trimble v. City of Santa Rosa, plaintiff's Fifth Amendment claim was not time-barred, and plaintiff may be able to show that he is entitled to damages, especially nominal damages, for the Miranda violation. Therefore, the court reversed the district court's dismissal of that claim. The court held that plaintiff properly pleaded a claim of Monell liability against the Sheriff's Department, and that the Sheriff's Department was subject to suit under section 1983 for its investigative activities. Therefore, the court reversed the district court's dismissal of this claim. Finally, the court affirmed the district court's dismissal of plaintiff's claim against the District Attorney's Office, but instructed it to grant plaintiff leave to amend his complaint to state a claim against District Attorney Murphy.
Court Description: Civil Rights. The panel reversed the district court’s dismissal of Frederick Jackson’s three claims brought against Ventura County officials and Departments under 42 U.S.C. § 1983, related to Miranda violations that resulted in the vacation of Jackson’s initial first degree murder conviction. Jackson’s initial first degree murder conviction was reversed due to a violation of his Miranda rights, and after a retrial, he was again convicted, this time without the use of the illegally obtained evidence. The panel reversed the district court’s rulings with respect to all three of Jackson’s claims in whole or in part. Regarding Jackson’s claim that Ventura County Sheriff Michael Barnes violated his Fifth Amendment rights by interrogating him without giving him the requisite Miranda warnings, the panel held that the claim is neither barred under Heck v. Humphrey, 512 U.S. 477 (1994), nor time-barred and that Jackson may be able to show that he was entitled to damages, if only nominal. Regarding Jackson’s claim that the Ventura County Sheriff’s Department violated his Fifth Amendment rights by failing to supervise Barnes, the panel reversed the district court’s judgment on the pleadings for the Sheriff’s Department because Jackson sufficiently pleaded a “policy of inaction” for which the Sheriff’s Department, as a county actor, was subject to suit under § 1983. The panel held that Jackson properly pleaded a claim of Monell v. N.Y.C. Dep’t of Soc. Servc., 436 U.S. 658 (1978), liability, and the Sheriff’s Department was subject to suit under 42 U.S.C. § 1983 for its investigative activities. The panel further held that the California Supreme Court’s holding in Vengas v. Cnty of L.A., 87 P.3d 1 (Cal. 2004), did not displace this court’s holding in Brewster v. Shasta Cnty., 275 F.3d 803, 807-08 9th Cir. 2001), that a California sheriff is a county official when investigating criminal activity. Finally, the panel affirmed the district court’s dismissal of Jackson’s claim of prosecutorial misconduct against the Ventura County District Attorney’s Office, but instructed the district court to grant Jackson leave to amend his complaint to state a claim against Ventura County District Attorney Patricia Murphy.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.