Hayes v. County of Kern, 24-193

Charles Hayes was arrested and extradited to California based on a warrant for a different individual.
Deputies Banks and Klawitter arrested Hayes, who possessed identification matching the name, birthdate, weight, and race in the extradition warrant.
Hayes asserted mistaken identity, highlighting differences between himself and the warrant subject, and protested his innocence multiple times.
Hayes sued under 42 U.S.C. § 1983 for alleged violations of his Fourth and Fourteenth Amendment rights, including claims against county deputies, a booking clerk (Hirrel), and the County of Kern.
The district court granted summary judgment to all defendants and Hayes appealed, but did not appeal some claims or defendants.
The Ninth Circuit affirmed, with a partial dissent regarding the due process claim against booking clerk Hirrel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for arrest under Fourth Amendment	Deputies lacked probable cause due to physical differences and repeated protests.	Deputies had probable cause based on facially valid warrant and matching ID.	No triable issue; judgment for defendants.
Due process violation for failure to investigate	Officials failed to investigate identity despite clear differences and protests.	No duty to further investigate with valid court order; clerk properly processed booking.	No triable issue; judgment for defendants.
Municipal liability under § 1983	County responsible for policy leading to constitutional violation.	No underlying constitutional violation or municipal policy at issue.	No triable issue; judgment for defendants.
Duty of booking clerk Hirrel to investigate identity	Clerk should have investigated further given discrepancies and protests.	Clerk's role limited; followed booking procedures; no policy violation.	No duty found; court affirms (with partial dissent).

Rivera v. Cnty. of Los Angeles, 745 F.3d 384 (9th Cir. 2014) (reasonable belief standard for mistaken identity arrests under warrant)
Garcia v. Cnty. of Riverside, 817 F.3d 635 (9th Cir. 2016) (due process requires reasonable investigation of identity when circumstances so demand)
Hill v. California, 401 U.S. 797 (1971) (aliases and false identification common during booking; citing standard for mistaken identity)
Fairley v. Luman, 281 F.3d 913 (9th Cir. 2002) (jury should decide if further investigation was warranted in mistaken identity incarceration)
Lockett v. Cnty. of Los Angeles, 977 F.3d 737 (9th Cir. 2020) (municipal liability requires underlying constitutional violation and official policy)