Sosa v. Martin Cnty.
| Decision Date | 20 January 2023 |
| Docket Number | 20-12781 |
| Citation | 57 F.4th 1297 |
| 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 |
Randall L. Kallinen, Alex Johnson, 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, Melissa Lynn Pietrzyk, Martin County Board of County Commissioners, Legal Dept., Stuart, FL, for Defendant-Appellee Martin County, Florida.
Summer M. Barranco, Purdy Jolly Giuffreda Barranco & Jisa, PA, Fort Lauderdale, FL, for Defendants-Appellees William Snyder, M. Killough, Sanchez.
Before William Pryor, Chief Judge, Wilson, Jordan, Rosenbaum, Jill Pryor, Newsom, Branch, Grant, Luck, Lagoa, and Brasher, Circuit Judges.
This appeal requires us to decide whether an individual detained for three days based on mistaken identity for a valid arrest warrant has stated a claim for relief under the Fourteenth Amendment for his over-detention. Deputy sheriffs arrested David Sosa based on a warrant for another man of the same name, detained him, and released him when his identity was verified three days later. Sosa sued the deputies for violating his alleged due-process right to be free from over-detention. But in Baker v. McCollan , the Supreme Court held that a detention due to mistaken identity "gives rise to no claim under the United States Constitution" when it lasts only "three days" and is "pursuant to a warrant conforming ... to the requirements of the Fourth Amendment." 443 U.S. 137, 144–45, 99 S.Ct. 2689, 61 L.Ed.2d 433 (1979). The district court dismissed Sosa's complaint for failure to state a claim. Because Baker squarely controls this case, we affirm and remand to the panel for the disposition of any remaining issues.
This appeal is from a dismissal for failure to state a claim, see FED. R. CIV. P. 12(b)(6), so we accept the allegations of the complaint as true. Henley v. Payne , 945 F.3d 1320, 1326 (11th Cir. 2019).
The Martin County Sheriff's Department twice has arrested David Sosa based on an arrest warrant for a different man with the same name. In 2014, a deputy sheriff stopped Sosa, a resident of Martin County, Florida, for a traffic violation. The deputy checked Sosa's driver's license using the sheriff's computer system and discovered a warrant issued 22 years earlier in Harris County, Texas for another man named David Sosa. Although Sosa protested during the traffic stop that the wanted man's date of birth, height, weight, social security number, and tattoo information did not match his own identifiers, deputies arrested, detained, and fingerprinted Sosa. After three hours, the sheriff's department confirmed his identity and released him.
Four years later, on Friday, April 20, 2018, another deputy sheriff checked Sosa's driver's license during a traffic stop and found the same Texas warrant. Again, Sosa objected that the identifiers listed on the warrant did not describe him. Sosa also told the deputies about the misidentification in 2014. Deputies arrested Sosa and brought him to the Martin County jail, where, despite Sosa's continued insistence to deputies and jailers that he was not the wanted man, his detention lasted three days over a weekend. On Monday, April 23, 2018, Sosa was fingerprinted, and the sheriff's department released him after the fingerprints confirmed that the warrant was for a different man.
Sosa filed a civil-rights action, see 42 U.S.C. § 1983, alleging violations of his rights under the Fourth Amendment and the Due Process Clause of the Fourteenth Amendment against Martin County; the Martin County Sheriff in his official capacity; Deputy Killough, the officer who arrested Sosa in 2018; Deputy Sanchez, an officer to whom Sosa protested his innocence during his three-day detention; and other unnamed deputies. Sosa alleged that the defendants "searched and detained and arrested him without probable cause or reasonable suspicion," that they took "an [u]nconstitutionally lengthy time" "to check [his] identity," and that the Sheriff and County "did not have adequate written policies, or train or supervise the deputies properly" to prevent Sosa's arrest.
The district court dismissed the complaint. See FED. R. CIV. P. 12(b)(6). It determined that Sosa had not plausibly alleged that the deputies had violated Sosa's rights under the Fourth or Fourteenth Amendments. And it held that because the deputies were not liable, there was no basis for liability against the Sheriff and County.
A panel of this Court affirmed in part and reversed in part. Sosa v. Martin Cnty. , 13 F.4th 1254, 1279 (11th Cir. 2021), reh'g en banc granted, op. , 21 F.4th 1362 (11th Cir. 2022). The panel opinion explained that the arrest was reasonable under the Fourth Amendment, id. at 1266, and that Sosa's claims against the County and the Sheriff were not viable, id. at 1279. The panel majority also concluded that Sosa stated a valid claim for violating his "substantive due-process right to be free from continued detention after it should have been known that [he] was entitled to release," id. at 1266, based on our precedent in Cannon v. Macon County , 1 F.3d 1558 (11th Cir. 1993). But the panel dissent concluded Baker fore-closed Sosa's over-detention claim. Sosa , 13 F.4th at 1279 (Luck, J., dissenting).
We voted in favor of rehearing the case en banc and vacated the panel opinion. Sosa , 21 F.4th at 1362. We instructed the parties to brief only issues related to the over-detention claim. And we heard oral argument only on those issues.
We review de novo a dismissal for failure to state a claim. Henley , 945 F.3d at 1326.
Our decision begins and ends with Baker . There, Leonard McCollan "procured" a driver's license that bore his own picture but, in all other respects, the information of his brother, Linnie. 443 U.S. at 140, 99 S.Ct. 2689. "Leonard, masquerading as Linnie, was arrested ... on narcotics charges," "booked as Linnie," and "released on bail as Linnie ...." Id. at 140–41, 99 S.Ct. 2689. Evidently, Leonard violated the terms of his bond because an arrest warrant was soon after issued for Linnie McCollan. See id. at 141, 99 S.Ct. 2689. When Linnie ran a red light, the police checked his driver's license, discovered the warrant, and arrested him, despite his protests of mistaken identity. Id. On Saturday, December 30, 1972, the police defendants took custody of Linnie "until [Tuesday,] January 2, 1973, when officials compared his appearance against a file photograph of the wanted man and, recognizing their error, released him." Id. Linnie later filed a civil-rights action alleging a violation of the Fourteenth Amendment. Id. After the Fifth Circuit reversed a directed verdict against Linnie on the theory that the police must "mak[e] sure that the person arrested and detained is actually the person sought under the warrant," McCollan v. Tate , 575 F.2d 509, 513 (5th Cir. 1978), the Supreme Court reversed and held that he had no constitutional right not to be detained for three days:
Absent an attack on the validity of the warrant under which he was arrested, respondent's complaint is simply that despite his protests of mistaken identity, he was detained ... from December 30 ... until January 2, when the validity of his protests was ascertained. Whatever claims this situation might give rise to under state tort law, we think it gives rise to no claim under the United States Constitution.
The Baker Court rejected Linnie's over-detention claim based on its consideration of only two criteria: the validity of Linnie's arrest warrant and the length of his detention. Id. It recognized that Linnie was "deprived of his liberty for a period of days," which spanned three days from Saturday to Tuesday. And it recognized that his detention was "pursuant to a warrant conforming ... to the requirements of the Fourth Amendment." Id. at 144, 99 S.Ct. 2689. It concluded based on these two facts that Linnie had no cognizable Fourteenth Amendment claim for over-detention.
As the Court explained, any other conclusion would read too much into the constitutional guarantee of due process. The Constitution does not guarantee that innocent people will never be arrested, so a detainee's claims of innocence are "largely irrelevant." Id. at 145, 99 S.Ct. 2689. Nor does the Constitution guarantee that officers will "investigate independently every claim of innocence ... based on mistaken identity." Id . at 146, 99 S.Ct. 2689. When officers do investigate, the Constitution does not guarantee an "error-free investigation." Id . And regardless of whether errors are made, the Fourteenth Amendment is not a constitutional bulwark against a few-days detention, "[g]iven the requirements that arrest be made only on probable cause [under the Fourth Amendment] and that one detained be accorded a speedy trial [under the Sixth Amendment.]" Id. at 145, 99 S.Ct. 2689. Even though the Due Process Clause affords protections to people deprived of their liberty, those protections do not extend to detainees in Linnie's particular situation.
Under Baker , no violation of due process occurs if a detainee's arrest warrant is valid and his detention lasts an amount of time no more than the three days that Linnie was detained. Id. at 144, 99 S.Ct. 2689. And both conditions are...
To continue reading
Request your trial