David Sosa v. Martin County, Florida, 20-12781

Background

Plaintiff David Sosa, a Florida resident, was mistakenly arrested twice (Nov. 2014 and Apr. 2018) by Martin County deputies on a 1992 Harris County, Texas warrant for a different "David Sosa." 2014 arrest: fingerprinted and released after ~3 hours. 2018 arrest: held ~3 days and 3 nights before fingerprint comparison confirmed misidentification.
At the 2018 booking Sosa repeatedly told deputies he was not the wanted man, gave differing identifying information (birthdate, SSN, height/weight, no tattoos), and said he had been previously misidentified; deputies wrote down his info and said they would follow up but did not verify identity for three days.
Sosa sued under 42 U.S.C. § 1983 against the Sheriff’s Department, Martin County, and individual deputies alleging: (1) Fourth Amendment false arrest; (2) Fourteenth Amendment overdetention (deliberate indifference); and (3) Monell failure-to-train/policy and failure to keep records to prevent repeat misidentifications. He sought damages and injunctive relief.
The district court dismissed the complaint for failure to state a claim. On appeal, the Eleventh Circuit affirmed dismissal of the false-arrest and Monell claims but reversed dismissal of the overdetention claim and remanded.
Key legal findings: (1) arrest on a valid warrant that reasonably matched name/critical descriptors was a reasonable mistake—deputy entitled to qualified immunity on false arrest; (2) detention after deputies learned facts raising substantial doubt about identity, coupled with three days of inaction, plausibly alleged Fourteenth Amendment deliberate indifference—qualified immunity denied for overdetention; (3) Monell failure-to-train/record claim insufficiently pleaded (no pattern of similar violations).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
False arrest (Fourth Amendment; qualified immunity)	Killough lacked arguable probable cause because warrant was for a different David Sosa and identifying data differed.	Valid warrant provided probable cause; roadside circumstances limited investigation; arrest was a reasonable mistake.	Arrest was a reasonable mistake under Rodriguez; deputy entitled to qualified immunity; false-arrest claim dismissed.
Overdetention (Fourteenth Amendment deliberate indifference)	Deputies (esp. Sanchez and booking staff) ignored repeated, specific ID discrepancies and failed to act for three days though fingerprint comparison would have promptly resolved identity.	Baker v. McCollan and related authority permit limited delay when detention is pursuant to a valid warrant; three-day detention on a warrant does not necessarily violate due process.	Allegations plausibly show deputies had subjective knowledge of substantial risk and did nothing for three days; deliberate indifference plausibly alleged and right clearly established by Cannon; claim survives qualified-immunity challenge and dismissal reversed.
Monell (municipal liability for failure to train/record)	County/Sheriff had no policies or records to prevent repeat misidentifications; failure to train/maintain records caused constitutional injury.	No underlying constitutional violation by deputies (on false arrest); plaintiff alleges only this incident—no pattern to put municipality on notice.	Monell claim dismissed: plaintiff failed to plead a pattern of similar violations or facts showing deliberate indifference by policymakers.

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard; accept well-pleaded factual allegations)
Baker v. McCollan, 443 U.S. 137 (1979) (detention under valid warrant with short delay does not necessarily violate Due Process)
Monell v. Dept. of Social Servs., 436 U.S. 658 (1978) (municipal liability requires policy/custom causing constitutional injury)
Cannon v. Macon Cnty., 1 F.3d 1558 (11th Cir. 1993) (failure to take steps to identify detainee over multi-day detention can show deliberate indifference)
Rodriguez v. Farrell, 280 F.3d 1341 (11th Cir. 2002) (reasonable-mistake test for misidentification arrests; critical identifiers and totality of circumstances)
Connick v. Thompson, 563 U.S. 51 (2011) (failure-to-train deliberate-indifference standard; need for pattern ordinarily required)
Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework; clearly-established-right analysis)
Saucier v. Katz, 533 U.S. 194 (2001) (sequence for qualified-immunity analysis; controlling precedent discussed)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (objective qualified-immunity standard)
Alcocer v. Mills, 906 F.3d 944 (11th Cir. 2018) (overdetention and deliberate indifference standard)