Myers v. Coats
2012 Ind. App. LEXIS 138
| Ind. Ct. App. | 2012Background
- Coats was mistakenly told to register as a sex offender despite never being convicted of a sex offense involving minors.
- Coats complied with registration requirements and sought to correct the erroneous listing; the registry listing inaccurately stated a conviction for criminal confinement of a minor.
- The Indiana Department of Correction (DOC) oversees the Registry; Myers is the DOC official responsible for maintenance and policy guidance.
- Coats attempted to obtain correction through internal DOC processes and later through federal court; he was ultimately removed from the Registry in federal litigation and then suit proceeded in state court under 42 U.S.C. § 1983.
- The trial court held that Coats had a liberty interest in not being mislabeled and that the process to correct the listing was inadequate; it found genuine issues of material fact as to Myers' personal deprivation, which this court later reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Myers personally deprived Coats of a liberty interest | Coats asserts personal involvement by Myers in failing to provide process. | Myers was not personally involved; policy decisions lie with the DOC Commissioner and the DOC, not Myers personally. | Yes; the court held Myers personally deprived Coats of a liberty interest. |
| Whether Coats received due process for erroneous registration | Due process required a hearing or meaningful opportunity to contest mislabeling. | Post-deprivation remedies and internal procedures were sufficient. | No; the process was insufficient; a hearing would have sufficed. |
| Whether the DOC procedures provided a sufficient pre-deprivation or post-deprivation remedy | DOC procedures were inadequate to contest erroneous listings. | DOC procedures, along with potential post-deprivation remedies, satisfied due process. | No; the procedures were not constitutionally adequate. |
Key Cases Cited
- Paul v. Davis, 424 U.S. 693 (U.S. 1976) (stigma-plus test for liberty interest de privations)
- Wallace v. State, 905 N.E.2d 379 (Ind. 2009) (sex offender registration imposes stigma and burden)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-part due process balancing test)
- Zinermon v. Burch, 494 U.S. 113 (U.S. 1990) (post-deprivation process may satisfy due process)
- Logan v. Zimmerman Brush Co., 455 U.S. 422 (U.S. 1982) (established state procedure mindset for process)
- Brown v. Montoya, 662 F.3d 1152 (10th Cir. 2011) (supervisory liability requires showing policy promulgation and involvement)
- J.H. Ex rel. Higgin v. Johnson, 346 F.3d 788 (7th Cir. 2003) (§ 1983 elements and color of state law)
- Conn. Dept. of Pub. Safety v. Doe, 538 U.S. 1 (U.S. 2003) (caution against due process limitations for sex-offender registries)