Appeals court upholds lawsuit against Sheriff for detaining the wrong person

A deputy from the Martin County Sheriff’s Office pulled over Sosa while driving.  After checking his name in the computer system and finding an outstanding warrant for a David Sosa, Sosa explained that he had been mistakenly arrested four years earlier for the same warrant.  He told the deputy about the differences between himself and the real Sosa who was wanted.  The deputy arrested him anyway, and he spent three days in jail before the sheriff’s office acknowledged he was not the wanted Sosa and released him.

Sosa filed a lawsuit pursuant to 42 U.S.C. §1983 against the Martin County Sheriff’s Department alleging a violation of his Fourth and Fourteenth amendment rights by falsely arresting him and for detaining him longer than he should have been detained.  He made a claim pursuant to Monell that the Sheriff failed to institute policies and train deputies to prevent these types of things from happening.  The trial court dismissed the case for failure to state a claim.

The Eleventh Circuit U.S. appeals court affirmed the trial court’s rulings dismissing the false arrest and the Monell claims, but it reversed the district court’s ruling as to the over-detention claim.  The court held that a protracted detention of an innocent person obviously interferes with a person’s liberty interests.  When a law enforcement officer receives information that suggests that he has the wrong person in custody, the Fourth and Fourteenth Amendments require him to take some action to resolve those doubts.   Sosa sufficiently alleged facts establishing that the Defendants failed to take any action for three days and nights after they learned of information that raised significant doubts about Sosa’s identity.

The appellate court found that the deputies at the jail had enough information to know that there was a substantial possibility that Sosa was not the wanted Sosa, that they had the means readily available to rapidly confirm Sosa’s identity.  Yet they took no action for three days and nights while Sosa sat in jail.  Only when they took his fingerprints, a standard police tool used for by every police force, did they easily and quickly conform that Sosa was not the wanted Sosa.  The appellate court found that the Sosa sufficiently alleged a violation of his Fourth Amendment due process right for over-detention and remanded the claim to the trial court.

As for the false arrest claim, the appeals court found that the deputy’s mistaken arrest of Sosa on the warrant was reasonable within the bounds of the Fourth Amendment.  The arrest happened on the roadside which limited the deputy’s ability to investigate Sosa’s claims of mistaken identity.  As for the differences between the information in the warrant and Sosa’s descriptive information, the appellate court found the differences were not material under the totality of the circumstances.   The fact that 26 years has passed between the time when the warrant was issued and when Sosa was arrested was significant to the extent that the differences were of not much importance in view of the passage of time.

The court denied Sosa’s Monell claim that the Sheriff and Martin County failed to train deputies to correctly identify a person wanted by his over-detention because Sosa failed to sufficiently allege a pattern of similar constitutional violations that would have put Martin County on notice of its need to train its deputies to correctly identify the target of a warrant.