Santiago Rivera v. County of Los Angeles, 2014 U.S. App. LEXIS 4646

Background

In 1985 Los Angeles Superior Court issued an arrest warrant for “Santiago Rivera” (true subject). In 1989 Montclair police mistakenly arrested a different Santiago Rivera (plaintiff); fingerprints then showed he was not the subject and the court issued a judicial clearance.
In 2009 deputies in San Bernardino arrested the plaintiff after a vehicle stop and a warrant check showed a 1989 warrant listing the same name and date of birth; plaintiff told deputies he had a prior judicial clearance but could not produce it.
Plaintiff was fingerprinted, transferred to Los Angeles custody, appeared before a judge the next day but did not assert mistaken identity at that first hearing; he later asserted it, was remanded while records were searched, and was released when fingerprints showed no match.
Rivera sued Los Angeles County, LA Sheriff’s Dept., San Bernardino County, and San Bernardino Sheriff’s Dept. under 42 U.S.C. § 1983 (Fourth and Fourteenth Amendments), the Bane Act, and for false imprisonment; district court granted summary judgment for defendants.
The Ninth Circuit majority affirmed: (1) the 1989 warrant met Fourth Amendment particularity; (2) deputies had reasonable, good-faith belief to arrest Rivera; and (3) post-arrest detention did not violate due process given prompt court process and absence of facts that should have put officials on notice he was entitled to release. The concurrence dissented as to the due-process holding.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrant particularity under the Fourth Amendment	Rivera: warrant was constitutionally insufficient because it lacked biometric/fingerprint identifiers, risking misidentification	County: warrant included name, DOB and physical description; particularity does not require fingerprints and a single mistaken arrest does not show municipal policy liability	Affirmed: warrant was sufficiently particular; no Monell showing of widespread policy or deliberate indifference
Lawfulness of arrest by San Bernardino deputies	Rivera: arrest was unreasonable because deputies should have accepted his claim of prior judicial clearance / mistaken identity	Deputies: name and DOB matched exactly; physical descriptors were similar; claim of mistaken identity uncorroborated so arrest was reasonable	Affirmed: deputies had probable cause and a reasonable, good-faith belief the arrestee was the warrant subject (Hill)
Post-arrest detention — Fourteenth Amendment due process	Rivera: detention after arrest and during records search violated due process; officials ignored his complaints and failed to check readily available exculpatory records	Counties: detainee had prompt judicial process (next-day hearing), absence of obvious indicia of misidentification, and officials may rely on court orders; no reason they should have known he was entitled to release	Reversed by concurrence but Majority affirmed summary judgment: no due-process violation because prompt court process and no facts that should have put defendants on notice he was entitled to release
State-law claims (false imprisonment, Bane Act) and statutory immunities	Rivera: state-law claims viable	Counties: statutory immunities shield officers and therefore counties; officers had reasonable belief and acted under warrant	Affirmed: statutory immunities apply; summary judgment for defendants

Key Cases Cited

United States v. Espinosa, 827 F.2d 604 (9th Cir. 1987) (Fourth Amendment particularity analysis of descriptive warrant)
White v. Olig, 56 F.3d 817 (7th Cir. 1995) (an arrest warrant naming the person is generally sufficiently particular)
Wanger v. Bonner, 621 F.2d 675 (5th Cir. 1980) (name on warrant satisfies particularity requirement)
Monell v. Department of Social Servs. of City of New York, 486 U.S. 658 (1978) (municipal liability requires policy or custom and deliberate indifference)
Hill v. California, 401 U.S. 797 (1971) (reasonableness of arrests made under a mistake of identity)
Fairley v. Luman, 281 F.3d 913 (9th Cir. 2002) (post-arrest detention can violate due process where procedures denied access and warnings of misidentification exist)
Baker v. McCollan, 443 U.S. 137 (1979) (short detention pursuant to a valid warrant did not violate due process; prolonged detention might)
Lee v. City of Los Angeles, 250 F.3d 668 (9th Cir. 2001) (distinguishes pre-arrest Fourth Amendment and post-arrest Fourteenth Amendment due-process claims)
Oviatt v. Pearce, 954 F.2d 1470 (9th Cir. 1992) (lengthy detention without arraignment can violate due process)
Bd. of Cnty. Comm’rs v. Brown, 520 U.S. 397 (1997) (single incident insufficient to establish municipal practice for Monell purposes)