Santiago v. Keyes
890 F. Supp. 2d 149
D. Mass.2012Background
- Plaintiff was arrested in Massachusetts based on a warrant allegedly matching his name but not his identity; he later disputed the warrant as mistaken identity.
- Rivera interrogated Plaintiff at the state police barracks; Plaintiff advised he was deaf and non-English speaker, claiming identity theft and misidentification.
- Plaintiff was arraigned in Chicopee District Court; the ADA allegedly informed the court fingerprints matched the warrant; Plaintiff was detained and later extradited to New York.
- New York Supreme Court later determined Plaintiff was not the proper subject of the warrant; Plaintiff spent 32 days in custody.
- Plaintiff asserts five counts; Counts I, II, and V pertain to both Keyes and Rivera, including federal civil rights and Massachusetts civil rights claims; other counts target other defendants.
- The court adjudicates motions to dismiss under Rule 12(b)(6), addressing official-capacity versus individual-capacity claims and whether MCRA requires threats, intimidation, or coercion distinct from a constitutional violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| MCRA claim against Keyes (individual capacity) survive? | Arrest without probable cause constitutes MCRA coercion. | Direct violation alone cannot satisfy MCRA; must be threats/intimidation/coercion. | Dismissal of Count V against Keyes in individual capacity |
| Keyes official-capacity claims under §1983/§1985 and MCRA viability? | Keyes, in official capacity, can be sued under MCRA. | State officials sued in official capacity are not 'persons' and cannot be liable; MCRA does not override. | Dismissal of official-capacity claims against Keyes |
| Rivera: 1985 claim viability and 1983 inaction claim viability? | Rivera failed to investigate; conspired with Keyes; potential 1983 liability for failure to intervene. | 1985 claim lacks animus or conspiracy; inaction viability is uncertain but may be pleaded. | 1985 claim against Rivera dismissed; 1983 inaction claim survives for now, subject to discovery |
| Rivera: MCRA claim viability and IIED claim viability? | Rivera perpetuated confinement and could be coercive under MCRA; IIED due to intentional or outrageous conduct. | No direct arrest by Rivera; no coercive acts pleaded; IIED not extreme or outrageous. | MCRA claim against Rivera dismissed; IIED claim against Rivera dismissed |
| Overall disposition of Keyes and Rivera claims? | Broadly pursue claims against Keyes and Rivera for violations of rights. | Many claims fail on pleading or capacity grounds; limit to viable individual-capacity claims. | Keyes: all claims dismissed in official capacity; Counts I and II survive in Keyes' individual capacity; Rivera: Counts I (1983), II (IIED) dismissed; Count I (1983) survives in Rivera's individual capacity; some claims allowed to proceed to discovery |
Key Cases Cited
- Planned Parenthood League of Massachusetts, Inc. v. Blake, 631 N.E.2d 989 (Mass. 1994) (direct action may include threats; coercion required for MCRA when not a direct violation)
- Longval v. Commissioner of Correction, 535 N.E.2d 588 (Mass. 1989) (direct violation does not by itself implicate the MCRA)
- Goddard v. Kelley, 629 F. Supp. 2d 115 (D. Mass. 2009) (coercion cannot be inferred from a bare false arrest)
- Gallagher v. Commonwealth of Massachusetts, 2002 WL 924243 (D. Mass. 2002) (direct violation cannot serve as MCRA coercion; separate element required)
- Nuon v. City of Lowell, 768 F. Supp. 2d 323 (D. Mass. 2011) (arrest without probable cause may support MCRA in some analyses)
- Will v. Michigan Dept. of State Police, 491 U.S. 58 (1989) (official-capacity suit is against the office, not the individual)