Lyttle v. United States
2012 U.S. Dist. LEXIS 46211
M.D. Ga.2012Background
- Lyttle, a U.S. citizen with diminished mental capacity, alleges ICE detained him without probable cause and deported him to Mexico.
- He was initially detained in North Carolina, then transferred to Georgia, where ICE pressured him and recorded false citizenship assertions.
- Hayes Memo and other ICE procedures allegedly required more robust investigation of citizenship claims, which allegedly were ignored.
- Lyttle was coerced into recording affidavits misidentifying him and was deported through Hidalgo, Mexico, wandering Central America for months.
- Subsequently, Lyttle returned to the U.S.; ICE re-detained him at Atlanta without proper verification, leading to further detention and removal actions.
- Lyttle also asserts FTCA and Rehabilitation Act claims, and seeks injunctive relief against several officials.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Bivens remedy availability | Lyttle seeks damages under Bivens for Fourth and Fifth Amendment violations. | INA precludes Bivens and immigration power is a political question. | INA does not bar a narrow Bivens remedy for U.S. citizens; some claims survive. |
| Individual-Defendant qualified immunity | Defendants violated Fourth/Fifth Amendments with no probable cause and disregard for citizenship evidence. | Defendants acted within discretion and are entitled to qualified immunity. | Several defendants lack qualified immunity for Fourth/Fifth Amendment claims; others granted immunity in part. |
| Official-capacity and standing for injunctive relief | Injunctive relief against officials is warranted to prevent future wrongful deportations; standing exists. | No standing and sovereign immunity bars official-capacity claims. | Official-capacity injunctive claims dismissed; standing lacking for Rehab Act injunctive relief. |
| FTCA false imprisonment, negligence, IIED | FTCA waives sovereign immunity for false imprisonment, negligence, and IIED under Georgia law. | Discretionary and due-care exceptions may bar FTCA claims; analysis required. | FTCA false imprisonment claim allowed; negligence and IIED claims viable under Georgia law; discretionary/due-care issues addressed. |
Key Cases Cited
- Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (U.S. 1971) (recognizes implied damages remedy for constitutional violations by federal agents)
- Hardison v. Cohen, 375 F.3d 1262 (11th Cir. 2004) (two-step inquiry for recognizing Bivens remedies)
- Wilkie v. Robbins, 551 U.S. 537 (U.S. 2007) (courts must weigh available remedies and policy factors for new damages actions)
- Carlson v. Green, 446 U.S. 18 (U.S. 1980) (recognizes limited Bivens actions and related principles)
- Minneci v. Pollard, 132 S. Ct. 617 (U.S. 2012) (limits Bivens remedies to context-specific considerations)
- Brignoni-Ponce, 422 U.S. 873 (U.S. 1975) (probable cause required for detention based on immigration status)
- Ng Fung Ho v. White, 259 U.S. 276 (U.S. 1922) (citizenship and due process protections in deportation context)
- Fong Yue Ting v. United States, 149 U.S. 698 (U.S. 1893) (distinction between citizen rights and deportation authority)
- Demore v. Kim, 538 U.S. 510 (U.S. 2003) (immigration detention considerations and due process context)
- Reno v. Am.-Arab Anti-Discrimination Comm., 525 U.S. 471 (U.S. 1999) (standards for immigrants’ constitutional rights and remedies)