Brown v. Ramsay, 4:18-cv-10279

Peter Sean Brown, a U.S. citizen, was arrested by Monroe County Sheriff’s Office (MCSO) for a probation violation in April 2018.
MCSO received and complied with an ICE detainer for Brown based on mistaken identity—ICE records documented this error from a previous 2005 incident.
Brown was repeatedly detained for several weeks after a state court ordered his release, despite his ongoing protests and offers to provide proof of citizenship.
MCSO had a policy of enforcing all ICE detainers without investigating claims of U.S. citizenship or contacting ICE for verification, though its own records showed Brown’s citizenship.
Brown filed suit under 42 U.S.C. § 1983 for Fourth Amendment unlawful seizure and a state law claim for false imprisonment, seeking declaratory and injunctive relief.
Both parties moved for summary judgment; the court granted Brown’s motion and denied the Sheriff’s, ruling in Brown’s favor on all counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MCSO had probable cause to detain Brown post-court-ordered release	Detainer was issued without probable cause; new information of citizenship dissipated probable cause	MCSO can rely on facially valid ICE detainer, need not investigate further	Detention was unlawful; MCSO must investigate new information (Brown wins)
Whether collective knowledge doctrine shields MCSO	Cannot ignore exculpatory evidence or claims of U.S. citizenship	Collective knowledge of ICE is sufficient; local officers can act on detainer	Doctrine does not insulate MCSO; must heed negating facts
False imprisonment under Florida law	Detention after valid authority evaporated was unlawful	Authority from BOA and ICE detainer precluded liability	Detention was without legal authority once probable cause dissipated; liability attaches
Entitlement to declaratory relief	Past wrongful detentions establish threat of future harm	No argument presented on standing	Brown entitled to declaratory judgment; MCSO enjoined from blind compliance with detainers

Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658 (municipal liability for constitutional violations requires a policy or custom)
Kingsland v. City of Miami, 382 F.3d 1220 (probable cause exists only if facts known to officer justify arrest; officers must heed information that dissipates probable cause)
Dunaway v. New York, 442 U.S. 200 (Fourth Amendment requires probable cause for seizures)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
Celotex Corp. v. Catrett, 477 U.S. 317 (burden-shifting framework under summary judgment)
Johnson v. Barnes & Noble Booksellers, Inc., 437 F.3d 1112 (elements of false imprisonment under Florida law)