Reginald Smith v. County of Los Angeles, 2:11-cv-10666

Background

In 1991 LASD recorded a felony no-bail warrant for a man identified as “Reggie Lamar Smith” / later identified as Robert Lee Cooks; the warrant used a 1962 birthdate that matched plaintiff Reginald Lenard Smith rather than Cooks.
LASD allegedly had or should have had information showing the true subject was Robert Cooks and that the warrant identifiers did not match Plaintiff; LASD had a prior incorrect incarceration of another Reginald Smith in 1997.
In 2007 Plaintiff (Reginald Smith) was arrested in Tennessee on the felony warrant, extradited to California, and held 13 days until a state court ordered release; a separate misdemeanor warrant also provided independent basis to hold him in California.
After Plaintiff’s August 2007 release the state court reissued the felony warrant but records again reflected Plaintiff’s name and birthdate; Plaintiff alleges later updates (2010) further added Plaintiff’s unique identifiers to Cooks’s warrant record.
In 2011 Plaintiff was arrested again after LAPD queried the County Warrant System (CWS) which relied on LASD-maintained records; Plaintiff also alleges a passport denial tied to the erroneous warrant entry.
Plaintiff sued under 42 U.S.C. § 1983 (Fourth and Fourteenth Amendments), California Constitution art. I, § 13, and state false imprisonment theories; defendants moved to strike and to dismiss several causes of action.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion to strike (Causes 4–6)	New claims are related to original amendment leave and not prejudicial; merits should be decided.	Claims exceed scope of leave and include scandalous material.	Denied — Court prefers to decide on merits; will address on 12(b)(6).
Fourth Amendment claim: preclusion and independent-authority defense	Smith alleges warrant was defective from the start (misidentified subject) and defendants concealed information, so prior rulings do not preclude relitigation.	Earlier district and Ninth Circuit rulings resolved warrant particularity and found independent bases (misdemeanor warrant, court order) to detain Smith, so claim is precluded or barred by independent authority.	Claim not precluded at pleading stage because Plaintiff alleges defendants misled prior courts; however Fourth Amendment liability is barred for detention Aug 15–22, 2007 (when misdemeanor warrant independently authorized detention); defendants remain potentially liable for Tennessee arrest, extradition, and detention under the later court order if they deliberately/recklessly misled the court.
Sixth Cause (false imprisonment and Cal. Const. art. I, § 13)	Asserts state false imprisonment and constitutional tort under § 13 based on same facts.	Preclusion and argument that § 13 is not self-executing for damages.	False imprisonment claim not precluded for same reasons as Fourth Amendment claim (but limited for Aug 15–22, 2007). Court recognizes a § 13 constitutional tort cause of action pursuant to Central District precedent.
Fifth Cause (due process claim relying on Cal. Penal Code § 11105)	Alleged due-process violation and unlawful disclosures/access to criminal-history information under § 11105 amount to a federal § 1983 violation.	Violation of state statute alone does not create a § 1983 claim; pleaded facts are conclusory and fail to show a protected liberty interest or concerted conspiracy.	Dismissed without prejudice. Court finds § 11105 alone does not clearly create the substantive federal liberty interest or mandatory procedural protections alleged; pleading insuficiently alleges facts (e.g., conspiracy or misuse) to state a § 1983 due-process claim.

Key Cases Cited

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard requires plausibility)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard and plausibility; need factual support for conclusions)
Taylor v. Sturgell, 553 U.S. 880 (federal common law governs preclusive effect; defines claim and issue preclusion)
Galen v. County of Los Angeles, 477 F.3d 652 (narrow exception when defendants deliberately or recklessly mislead judicial officer such that court order does not break causation)
Bravo v. City of Santa Maria, 665 F.3d 1076 (apply tort proximate-cause principles to § 1983 claims)
Tatum v. Moody, 768 F.3d 806 (officers cannot escape liability by pointing to officials they misled)
Gonzalez v. Spencer, 336 F.3d 832 (Ninth Circuit allowed a § 1983 claim grounded in state statute protecting juvenile records; discussed limits on informational-privacy-based federal claims)
Brigham City v. Stuart, 547 U.S. 398 (Fourth Amendment reasonableness standard)