Moya v. Garcia
895 F.3d 1229
10th Cir.2018Background
- Moya and Petry were arrested on outstanding indictments/warrants and detained in Santa Fe County jail for 30+ days without arraignment, allegedly violating New Mexico Rule 5-303(A) (arraignment within 15 days).
- They sued under 42 U.S.C. § 1983 against the sheriff and two wardens in their individual capacities (personal/supervisory liability) and the County (municipal liability) for deprivation of due process based on overdetention.
- The district court dismissed the complaint for failure to state a claim; plaintiffs sought leave to amend, which was denied.
- The Tenth Circuit panel affirmed dismissal, holding plaintiffs did not plausibly allege facts attributing causation of the arraignment delays to the sheriff/wardens; arraignment scheduling was controlled by the state court.
- The panel also affirmed dismissal of municipal claims because the alleged inaction by county officials did not cause the delay; leave to amend was denied as futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiffs pleaded personal/supervisory liability against sheriff/wardens for due‑process overdetention | Moya/Petry: jail officials failed to implement policies/procedures to prevent overdetention and thus caused deprivation of liberty | Defs: arraignments are scheduled by the state court; jail officials lacked authority to cause or cure delays | Held: Dismissed—complaint fails to plausibly attribute causation to sheriff/wardens because scheduling power lay with the court |
| Whether defendants violated a clearly established constitutional right (qualified immunity) | Moya/Petry: right to timely arraignment and pretrial liberty were clearly established | Defs: no controlling precedent clearly establishes jailers violate Constitution by not scheduling court-ordered arraignments | Held: Court assumed without deciding there might be a constitutional violation but concluded plaintiffs failed to plead causation; qualified immunity analysis unnecessary for majority outcome |
| Municipal liability of County under Monell for failure to adopt policy to ensure timely arraignments | Moya/Petry: County policy/inaction caused systemic overdetention | County: municipal liability requires that county policy or custom caused constitutional violation; here county did not cause delays | Held: Dismissed—County not liable because alleged inaction by county officials did not cause arraignment delays |
| Whether district court abused discretion by denying leave to amend | Moya/Petry: amendment could cure pleading defect; should be allowed | Defs: amendment would be futile because plaintiffs cannot plausibly allege that jailers caused the delays | Held: Denial affirmed—plaintiffs failed to identify how amendment would cure lack of causation |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (application of plausibility standard and pleading rules)
- Dodds v. Richardson, 614 F.3d 1185 (10th Cir. 2010) (supervisory liability and causation in § 1983 overdetention claims)
- Wilson v. Montano, 715 F.3d 847 (10th Cir. 2013) (sheriff/warden liability where deputies arrested without warrant and jail prevented probable-cause process)
- Jauch v. Choctaw Cty., 874 F.3d 425 (5th Cir. 2017) (county policy of holding detainees until court reconvened caused prolonged detention)
- Hayes v. Faulkner Cty., 388 F.3d 669 (8th Cir. 2004) (extended detention without timely first appearance violated due process; jailers held responsible)
- Armstrong v. Squadrito, 152 F.3d 564 (7th Cir. 1998) (jailers’ knowledge/control over detainees supports supervisory liability for overdetention)
- Oviatt ex rel. Waugh v. Pearce, 954 F.2d 1470 (9th Cir. 1992) (sheriff must enact procedures to avoid erroneous prolonged incarcerations)
- Estate of Brooks ex rel. Brooks v. United States, 197 F.3d 1245 (9th Cir. 1999) (county not cause of overdetention where it lacked authority to produce detainee before federal judge)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework)