Goodall v. Quick Collect, Inc., 6:15-cv-01887

Plaintiff Michael Goodall (Sr.) shares a name with his son, Michael Goodall Jr.; Quick Collect obtained a judgment and sought post-judgment process against “Michael Goodall.”
Quick Collect used DMV data to populate a civil bench warrant; the warrant’s identifying information (name, DOB, driver’s license, height/weight) matched Goodall Sr., though the underlying debt belonged to Goodall Jr.; the SSN on the warrant belonged to Jr.
Marion County issued and Sheriff’s deputies executed the civil bench warrant for the named subject; Plaintiff went to the sheriff’s office, was arrested, booked, held ~7 hours, and then released.
Plaintiff sued under 42 U.S.C. § 1983 alleging Fourth and Fourteenth Amendment violations (false arrest/mistaken identity) and asserted collateral harms (failed background checks affecting foster work and a concealed-weapons permit).
Defendants moved for summary judgment; Plaintiff conceded John Doe was unserved; the court considered whether arrest pursuant to a facially valid warrant deprived Plaintiff of constitutional rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of arrest under Fourth Amendment	Arrest was mistaken identity; warrant intended for Jr., so no valid basis to arrest Sr.	Warrant facially named Michael Goodall with matching identifiers; deputies had probable cause to arrest the named subject.	Arrest valid as a matter of law because warrant facially identified Plaintiff; summary judgment for Myers.
Duty to investigate claims of mistaken identity (Due Process)	Deputies had a constitutional duty to investigate Plaintiff's assertions and the incorrect SSN.	No constitutional duty to independently investigate every claim of innocence or resolve identity disputes; process belongs to courts.	No Fourteenth Amendment violation; no duty to perform exhaustive investigation at arrest.
Monell liability against county/sheriff’s office	County policies/customs caused deliberate indifference leading to constitutional violation.	Sheriff’s office relied on nonexclusive identifying factors and acted on a facially valid warrant; no policy-based constitutional violation.	Monell claim dismissed for lack of evidence of policies causing constitutional deprivation.
First/Second Amendment harms from collateral consequences	Loss of foster placement and conceal carry eligibility amounted to constitutional deprivations.	No constitutional right to a concealed-carry permit; foster-parent relationship not a protected liberty interest.	Claims under First and Second Amendments fail as a matter of law.

Baker v. McCollan, 443 U.S. 137 (1979) (arrest pursuant to a facially valid warrant generally precludes a Fourth Amendment claim despite mistaken identity)
Hill v. California, 401 U.S. 797 (1971) (officers who reasonably mistake a person for the one named in a valid warrant do not violate the Fourth Amendment)
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires a policy or custom that is the moving force behind a constitutional violation)
Fairley v. Luman, 281 F.3d 913 (9th Cir. 2002) (pretrial detention/mistaken-identity issues analyzed under the Fourteenth Amendment)
Peruta v. County of San Diego, 824 F.3d 919 (9th Cir. 2016) (no constitutional right to a concealed-weapons permit)