Jessica Jauch v. Choctaw County
2017 U.S. App. LEXIS 21029
| 5th Cir. | 2017Background
- Jessica Jauch was arrested on a Choctaw County capias (misdemeanor/sale of controlled substance indictment) and held in county jail after a traffic stop on April 26, 2012.
- Jail officials refused her repeated requests to be brought before a judge or allowed to post bail, telling her she could not be seen until the next circuit court term; she remained detained 96 days before any court appearance.
- After 96 days she received appointed counsel, waived formal arraignment, bail was set, and she posted bail six days later; the prosecutor soon moved to dismiss and the indictment was later dismissed.
- Jauch sued under 42 U.S.C. § 1983 against Sheriff Halford and Choctaw County alleging violations of the Sixth, Eighth, and Fourteenth Amendments; the district court granted summary judgment to defendants.
- The Fifth Circuit reversed as to the Fourteenth Amendment procedural due process claim, holding indefinite pretrial detention without a prompt judicial appearance violated due process, and found Choctaw County liable under Monell; it also denied qualified immunity for the sheriff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prolonged pretrial detention without a prompt court appearance violates the Fourteenth Amendment procedural due process | Jauch: indefinite detention (96 days) without arraignment or judicial review deprived her of protected liberty and basic procedural due process | Defendants: arrest was supported by grand-jury probable cause; Fourth Amendment governs and no constitutional violation occurred | Held: Fourteenth Amendment procedural due process violated — Medina/ Jones framework shows indefinite detention without court review is unconstitutional |
| Whether the Fourth Amendment exclusively governs pretrial-detention claims where arrest was with probable cause | Jauch: due process claim available even after lawful seizure; prolonged detention raises Fourteenth Amendment concerns | Defendants: because arrest was supported by probable cause, only Fourth Amendment analysis applies and that was satisfied | Held: Fourth Amendment not exclusive; legally seized detainees may bring Fourteenth due process claims for prolonged detention (citing Jones and Manuel guidance) |
| Whether Choctaw County is liable under Monell for the detention policy | Jauch: county (via sheriff) maintained a policy/custom of holding detainees until next court term, causing constitutional harm | Defendants: deny municipal liability; contend no official policy causing the violation | Held: County liable — sheriff was final policymaker and the indefinite-detention practice was an official policy and the moving force behind the violation |
| Whether Sheriff Halford is entitled to qualified immunity | Jauch: right was clearly established (Jones precedent) and sheriff knowingly or negligently enforced unconstitutional procedure | Halford: functions of other state officials (e.g., judges) preclude imposing federal liability on sheriff; relied on state-law defenses | Held: Qualified immunity denied — the right against prolonged detention without judicial appearance was clearly established and sheriff failed to honor constitutional duties |
Key Cases Cited
- Jones v. City of Jackson, 203 F.3d 875 (5th Cir. 2000) (pretrial detention for months without a hearing implicates Fourteenth Amendment due process)
- Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires an official policy or custom that is the moving force behind a constitutional violation)
- Medina v. California, 505 U.S. 437 (1992) (limits the Mathews balancing test for procedural rules that are part of the criminal process; due process test for state criminal procedures)
- Gerstein v. Pugh, 420 U.S. 103 (1975) (probable-cause determination requirement for extended pretrial detention; distinction between initial seizure and continued detention)
- Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (Fourth Amendment governs challenge to detention lacking probable cause, but does not foreclose Fourteenth Amendment claims after lawful seizure)
- Klopfer v. State of North Carolina, 386 U.S. 213 (1967) (right to speedy trial is fundamental; historical sources support prompt proceedings)
- Anderson v. Creighton, 483 U.S. 635 (1987) (qualified-immunity standard: right must be clearly established such that a reasonable official would understand the conduct was unlawful)