Mario Garcia v. County of Riverside
2016 U.S. App. LEXIS 6572
| 9th Cir. | 2016Background
- Mario A. Garcia arrested for DUI in Riverside County (Nov. 2012); Livescan fingerprints sent to CA DOJ produced a CII tied to Garcia, but a 1994 LA felony warrant existed for a different Mario L. Garcia sharing the same name and birthdate.
- Riverside officers located the 1994 LA warrant and, after an inter-agency “hit,” detained Garcia despite his protests that he was not the warrant subject.
- Garcia alleges LA County Sheriff’s Department (LASD) personnel did not provide or compare biometric identifiers (fingerprints/CII), middle name, or criminal history that would have shown the persons were different.
- Garcia alleges LASD policy/systems discouraged use of CII or fingerprint checks and ignored detainee complaints of misidentification.
- Procedurally: district court denied defendants’ motions for qualified immunity (Baca), quasi-judicial immunity, and state-law statutory immunities; defendants appealed; Ninth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether detention on a warrant for another person can violate Fourteenth Amendment due process | Garcia: detention violated due process because obvious discrepancies (9" height, 40 lb weight, different middle name, fingerprints/CII) and his protests put officers on notice to investigate | Defendants: Baker controls; a valid warrant dispenses with a duty to investigate identity absent clear reason; no constitutional violation | Held: A due process claim may lie where circumstances (height/weight differences, biometric mismatch, complaints) indicated further investigation was warranted; Garcia pleaded a plausible Fourteenth Amendment violation |
| Whether Baca is entitled to qualified immunity for the alleged due process violation | Garcia: law was clearly established (Lee, Fairley, Rivera, Gant) that officers must investigate when circumstances demand | Baca: law was not clearly established; Baker and related precedents permit reliance on a facially valid warrant; qualified immunity applies | Held: Law was clearly established; Baca is not entitled to qualified immunity |
| Whether Baca (individually) is entitled to absolute/quasi-judicial immunity for executing a facially valid warrant | Garcia: claim targets misapplication/lack of identity-verification procedures, not the warrant’s issuance | Baca: executing a judicial order entitles officials to absolute immunity from § 1983 liability | Held: Quasi-judicial immunity does not cover alleged failures to comply with order’s proper application (i.e., booking the wrong person); Baca not entitled to absolute immunity on pleaded facts |
| Whether LA County and LASD have California statutory immunities for false arrest/false imprisonment | Garcia: claims concern detention on a warrant by county actors, not the original arresting officers; statutory immunities in Penal Code §847 and Civ. Code §43.55 apply only to arresting officers or are premised on a reasonable belief | Defendants: statutes shield peace officers who arrest pursuant to warrants or who reasonably believed arrest lawful | Held: Statutory immunities do not apply because Garcia’s suit challenges continued detention based on a misapplied warrant and alleges officers lacked a reasonable basis to believe he was the warrant subject; statutes aimed at arresting officers do not bar these claims |
Key Cases Cited
- Baker v. McCollan, 443 U.S. 137 (Sup. Ct.) (holding arrest pursuant to a facially valid warrant does not automatically create a due process violation absent special circumstances)
- Rivera v. County of Los Angeles, 745 F.3d 384 (9th Cir.) (officers must investigate further when circumstances indicate misidentification is likely)
- Lee v. City of Los Angeles, 250 F.3d 668 (9th Cir.) (municipal liability where conscious failure to train led to mistaken identity detentions)
- Fairley v. Luman, 281 F.3d 913 (9th Cir.) (due process violation where booking proceeded despite significant discrepancies and no fingerprint check)
- Gant v. County of Los Angeles, 772 F.3d 608 (9th Cir.) (distinguishing when prompt hearing or lack of notice defeats a due process claim; reversing summary judgment where disputes existed whether detainee complained)
- Pearson v. Callahan, 555 U.S. 223 (Sup. Ct.) (qualified immunity two-step: constitutional violation and clearly established law)
- Mitchell v. Forsyth, 472 U.S. 511 (Sup. Ct.) (appealability of immunity denials under collateral order doctrine)
- Monell v. Department of Social Services, 436 U.S. 658 (Sup. Ct.) (municipalities cannot claim absolute immunity under §1983)
- Engebretson v. Mahoney, 724 F.3d 1034 (9th Cir.) (limits of absolute immunity for executing facially valid court orders)
- Owen v. City of Independence, 445 U.S. 622 (Sup. Ct.) (official-capacity vs individual-capacity immunity distinctions)