Nicole Schneyder v. Gina Smith
2011 U.S. App. LEXIS 15831
| 3rd Cir. | 2011Background
- Schneyder, a material witness in Overby’s Pennsylvania case, was jailed for weeks after a warrant issued Jan 26, 2005 due to feared nonappearance.
- Judge Means ordered detention for Schneyder upon failure to post a $300,000 surety, with a plan to reassess if the trial date changed.
- The Overby trial was continued from Feb 2 to May 25, 2005, but the court was not informed and Schneyder remained jailed.
- Attorney Gina Smith, as ADA, failed to notify Judge Means of the continuance or changes in the case status.
- Schneyder’s family and a public defender prompted discovery that the trial delay persisted; Schneyder was released March 21, after 54 days.
- Schneyder sued Smith under 42 U.S.C. § 1983 alleging Fourth Amendment rights were violated by the failure to inform the court of the continuance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fourth Amendment applies to material-witness detention | Schneyder’s detention is a Fourth Amendment seizure. | Detention is not a seizure under Fourth Amendment because not a criminal arrest. | Yes; applying continuing-seizure theory, Fourth Amendment governs detention. |
| Whether Smith’s failure to notify court caused the violation | Smith’s non-disclosure proximately caused unlawful detention. | No causal link or no violation of rights. | Smith’s failure was a substantial factor; liable under § 1983. |
| Whether the right was clearly established to defeat qualified immunity | Existing law clearly established a duty to inform the court of status changes. | Right not clearly established; conduct could be discretionary. | Right was clearly established; Smith not immune. |
| Whether absolute prosecutorial immunity applies | Administrative negligent failure falls outside advocacy. | Van de Kamp supports absolute immunity for supervisory roles. | Absolute immunity does not apply; § 1983 claim survives. |
Key Cases Cited
- Gallo v. City of Philadelphia, 161 F.3d 217 (3d Cir.1998) (adopted continuing-seizure theory for pretrial detention)
- Albright v. Oliver (Ginsburg concurrence), 510 U.S. 266 (1994) (continuing-seizure concept for pretrial restraint)
- Al-Kidd v. Ashcroft (al-Kidd II), 131 S. Ct. 2074 (2011) (material-witness seizure governed by Fourth Amendment; reasonable-detention standard)
- Gerstein v. Pugh, 420 U.S. 103 (1975) (probable cause and post-arrest judicial review framework)
- Hope v. Pelzer, 536 U.S. 730 (2002) (fair-warning standard for clearly established rights)
- Van de Kamp v. Goldstein, 555 U.S. 335 (2009) (absolute-immunity boundaries for supervisory prosecutors; direct-trial connection)
- Anderson v. Creighton, 483 U.S. 635 (1987) (clearly established standard; objective reasonableness)
- Torres v. McLaughlin, 163 F.3d 169 (3d Cir.1998) (limits of Fourth Amendment protection between arrest and pretrial detention)