Michael Segaline v. State Of Wa, Dept. Of L & I
76010-6
| Wash. Ct. App. | Jul 17, 2017Background
- In June 2003 L&I employees reported Michael Segaline for threatening/harassing conduct at the East Wenatchee Department of Labor & Industries (L&I) office; Regional Safety and Health Coordinator Alan Croft drafted and issued a trespass notice barring Segaline from the office.
- Police were involved on multiple visits; Segaline was later arrested for criminal trespass (charge dismissed).
- Segaline sued L&I and later amended to add Croft under 42 U.S.C. § 1983, alleging a Fourteenth Amendment liberty interest to enter a public office was violated without due process.
- Lower courts previously dismissed some claims; after remands the trial court allowed the § 1983 claim to proceed, excluded the question whether the trespass notice’s legality was clearly established, and instructed the jury on Mathews-type due process factors.
- A jury found for Segaline on the § 1983 claim and awarded substantial damages; the Department and Croft appealed arguing Croft was entitled to qualified immunity and the court erred by submitting the due process legal question to the jury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Croft violated a clearly established due process right by issuing the trespass notice in 2003 | Segaline: issuance deprived him of a liberty interest to enter a public office without adequate notice and opportunity to be heard (continuing violation theory) | Croft: no clearly established law in 2003 put him on notice that issuing the trespass notice would violate due process; he consulted law enforcement and counsel and acted reasonably | Held: Segaline failed to show a clearly established right in 2003; Croft entitled to qualified immunity as a matter of law |
| Whether the trial court erred by denying judgment as a matter of law dismissing the § 1983 claim | Segaline: factual disputes (continuing violation, lack of process) precluded JMOL | Croft: even accepting facts in plaintiff’s favor, qualified immunity requires dismissal | Held: Court erred in denying JMOL; qualified immunity required dismissal |
| Whether the jury should decide application of Mathews due process balancing | Segaline: jury may assess the factual application of process factors | Croft: what process is due is a legal question for the judge; jury should not decide legal standard | Held: Trial court erred by instructing jury on legal due process factors; judge should decide what process is due |
| Whether post-2003 cases and district-court decisions establish a clearly established right | Segaline: later cases (including State v. Green and some federal decisions) show due process required before broad trespass restrictions | Croft: later decisions are not relevant to the 2003 clearly established inquiry; district court opinions are not controlling authority | Held: Later decisions and district-court cases do not establish the 2003 legal standard; they are not sufficient to defeat qualified immunity |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework and early resolution of immunity questions)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established right standard requires controlling authority or robust consensus)
- Harlow v. Fitzgerald, 457 U.S. 800 (objective reasonableness standard for qualified immunity)
- Mathews v. Eldridge, 424 U.S. 319 (balancing test for procedural due process)
- Zinermon v. Burch, 494 U.S. 113 (deprivation without due process violates the Constitution)
- Anderson v. Creighton, 483 U.S. 635 (warning against defining clearly established rights at high level of generality)
- Saucier v. Katz, 533 U.S. 194 (when law did not put official on notice, claim should not proceed)
- Brosseau v. Haugen, 543 U.S. 194 (context-specific clearly established inquiry)