Sosa v. Martin Cnty.

• Decision Date: 20 September 2021
• Docket Number: No. 20-12781,20-12781
• Citation: 13 F.4th 1254
• Parties: David SOSA, Plaintiff-Appellant, v. MARTIN COUNTY, FLORIDA, Sheriff William Snyder, of Martin County, Florida in an official capacity, Deputy M. Killough, individually, Deputy Sanchez, individually, John Doe Martin County Deputies, Defendants-Appellees.
• Court: U.S. Court of Appeals — Eleventh Circuit

13 F.4th 1254

David SOSA, Plaintiff-Appellant,

v.MARTIN COUNTY, FLORIDA, Sheriff William Snyder, of Martin County, Florida in an official capacity, Deputy M. Killough, individually, Deputy Sanchez, individually, John Doe Martin County Deputies, Defendants-Appellees.

No. 20-12781

United States Court of Appeals, Eleventh Circuit.

September 20, 2021

Randall L. Kallinen, Kallinen Law, PLLC, Houston, TX, Harris W. Gilbert, Gilbert & Smallman, PLLC, Hollywood, FL, for Plaintiff-Appellant.

Summer M. Barranco, Purdy Jolly Giuffreda Barranco & Jisa, PA, Fort Lauderdale, FL, Robert David Arthur, II, Martin County Attorney's Office, Stuart, FL, for Defendant-Appellee Martin County.

Summer M. Barranco, Purdy Jolly Giuffreda Barranco & Jisa, PA, Fort Lauderdale, FL, for Defendants-Appellees William Snyder, M. Killough, Sanchez.

Before MARTIN, ROSENBAUM, and LUCK, Circuit Judges.

ROSENBAUM, Circuit Judge:

David Sosa may have cursed his luck when the Martin County Sheriff's Department pulled him over for a traffic violation in November 2014. "[W]hen ill luck begins, [though,] it does not come in sprinkles, but in showers."¹ And so it was for Sosa.

When the officer ran Sosa's name, the computer indicated an outstanding Harris County, Texas, warrant from 1992 for a different David Sosa (the "wanted Sosa"). Though some of the identifying details for the wanted Sosa and Sosa differed, the deputy arrested Sosa and took him back to the station. There, deputies fingerprinted Sosa, and he spent three hours in jail before they determined that he was not the wanted Sosa.

Three-and-a-half years later, it happened again! On April 20, 2018, the same Martin County Sheriff's Department (though a different deputy) stopped Sosa as he drove. Once again, the deputy checked Sosa's name in the computer system and found the same outstanding warrant for the wanted David Sosa. Sosa told the deputy about his mistaken 2014 arrest on that warrant and advised the deputy of differences between himself and the wanted Sosa. But once again, the deputy arrested him and took him back to the station. This time, though, Sosa had to spend three days and nights in jail before the Department acknowledged that he was not the wanted Sosa and finally released him.

Trying to avoid a third stay at the county jail for someone else's misdeeds, Plaintiff-Appellant Sosa filed this 42 U.S.C. § 1983 suit against the Defendants-Appellees Martin County Sheriff's Department and the deputies involved in the second incident. In it, Sosa alleged that the Defendants-Appellees violated his Fourth and Fourteenth Amendment rights by falsely arresting him, overdetaining him, and failing to institute policies and train deputies to prevent these things from happening (the " Monell claim"² ). The district court dismissed the case with prejudice for failure to state a claim. We now affirm the district court's rulings on the false-arrest and Monell claims and reverse on the overdetention claim.

Detention—and particularly protracted detention—of an innocent person obviously seriously interferes with that person's liberty interests. So when a law-enforcement officer receives information that suggests that he has the wrong person in custody, the Fourteenth Amendment requires him to take some action to resolve those doubts. Because Sosa sufficiently alleged facts establishing that Defendants-Appellees failed to take any action for three days and nights after they learned of information that raised significant doubts about Sosa's identity, we vacate the district court's order dismissing the overdetention claim and remand for further proceedings.

I.

As we've mentioned, Sosa had the misfortune to be arrested and detained twice by Defendants on the same outstanding warrant for a different David Sosa. Before we summarize the allegations in more detail, we pause to note that this is an appeal of an order dismissing Sosa's case for failure to state a claim, so for purposes of our analysis, we accept as true the factual allegations from Sosa's First Amended Complaint. See Ashcroft v. Iqbal , 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009).

According to that filing, Sosa has lived in Martin County, Florida, since 2014. There, he works for Pratt and Whitney and its affiliates in research and development on airplane engines.

While Sosa was driving in Martin County, in November 2014, a Martin County Sheriff's deputy pulled him over for a routine traffic stop. During the encounter, the deputy reviewed Sosa's driver's license. After running Sosa's name through the Department's computer system, the deputy learned that an outstanding warrant for a David Sosa had been issued out of Harris County, Texas, in connection with that David Sosa's conviction for selling crack cocaine in 1992. The warrant set forth identifying characteristics for the wanted David Sosa, including his date of birth, height, weight, tattoo information (he had at least one), and other details. Plaintiff-Appellant Sosa pointed out to the officer that his own date of birth, height, and weight—a 40-pound difference between himself and the wanted David Sosa existed—did not match the information for the wanted Sosa and that, unlike the wanted Sosa, he had no tattoos. The deputies arrested Sosa, anyway, and took him to the station.

There, they fingerprinted and detained him. Sosa told two Martin County jailers that he was not the wanted Sosa and explained that identifiers like date of birth differed between the two. After about three hours, a deputy determined that Sosa was not the wanted Sosa and released him.

But no one created a file or otherwise documented that Sosa was not the wanted Sosa. Nor did the Sheriff's Department have any system to prevent Sosa's future mistaken arrest on the wanted Sosa's warrant.

So perhaps not that surprisingly, Sosa had a similar misadventure not long after his 2014 incident. On April 20, 2018, a different deputy of the Martin County Sheriff's Department, Deputy Killough, pulled Sosa over for a traffic stop. Sosa provided Killough with his license, and when Killough ran it, he discovered the open warrant for the wanted Sosa. Sosa explained that he was not the wanted Sosa and told Killough he had previously been incorrectly arrested on that warrant and released when deputies realized the error. Sosa also noted that he and the wanted Sosa did not share the same birthdate, Social Security number, or other identifying information.

But Killough arrested Sosa and impounded his truck, anyway. When Killough took Sosa to the Martin County jail, Sosa "repeatedly explained to many Martin County employees ... that his date of birth and other identifying information was different than the information on the warrant for the wanted ... Sosa." In particular, Sosa so advised Deputy Sanchez and some other Martin County deputies in the booking area. They wrote down Sosa's information and told him they would follow up on the matter.

The next day, Sosa appeared by video before a magistrate judge. Though Sosa attempted to explain the mistaken identity, "several Martin County jailers threatened him and told him not to talk to the judge during his hearing." As a result, Sosa believed it was a crime to talk to the judge.

Finally, on April 23, deputies fingerprinted Sosa and then released him at about 3:00 p.m. In the meantime, he had missed work and then had to pay to retrieve his truck from impoundment.

Though the Sheriff's Department twice arrested and detained Sosa in error on the wanted Sosa's Texas warrant, the Sheriff's Department still created no file or other documentation to prevent the same thing from happening yet again.

Sosa had enough, and he filed suit against Martin County and the individual deputies. In his Amended Complaint, he brought a single count under 42 U.S.C. § 1983 for violations of his constitutional rights. The claim asserted that Martin County, the Sheriff's Department, and the individual deputies violated Sosa's Fourth and Fourteenth Amendment rights by arresting and detaining him without probable cause or reasonable suspicion. It also alleged that the Sheriff and the County lacked adequate written policies and failed to train and supervise the deputies properly concerning arrests on outstanding warrants.

Sosa's complaint sought injunctive relief precluding the Martin County Sheriff's Department from arresting and detaining Sosa on the wanted Sosa's warrant, requiring the Sheriff and the County to maintain a file on Sosa as it relates to the wanted Sosa's warrant, and directing the Sheriff and the County to implement policies and train employees to avoid arresting and detaining individuals who are not wanted but who have the same names as those for whom a warrant is outstanding. The complaint also demanded compensatory and punitive damages and attorney's fees and costs.

Besides that, Sosa indicated his intentions to seek to represent and certify two classes: (1) a class of all David Sosas who are not the wanted Sosa and (2) a class of all "individuals falsely arrested or detained on warrants," where the person arrested or detained, or both, was not the person identified in the outstanding warrant.

Martin County moved to dismiss and separately, the Sheriff, Killough, and Sanchez filed their own motion to dismiss. The County first asserted that it could not be held responsible for the Sheriff's actions. In the alternative, it, along with the Sheriff, contended Sosa failed to make out a Monell claim because he did not establish that they had a policy or custom that caused the deprivation of his rights. Deputies Killough and Sanchez asserted that they were entitled to qualified immunity.

The district court granted the motions to dismiss. It concluded that the deputies did not violate Sosa's constitutional rights with either their arrest or detention of Sosa, so it did not reach the question of qualified immunity on either issue. As for Sosa's Monell claim against Martin County and the Sheriff in his official capacity, ...