Garcia v. Cnty. of Riverside

Plaintiff filed suit under 42 U.S.C. 1983, the California Constitution, and state tort law, alleging that he was wrongfully incarcerated by LASD based on the misapplication of a felony warrant issued in 1994 for Mario L. Garcia, who has the same date of birth as plaintiff. On appeal, LASD, and former LA Sheriff Lee Baca challenged the district court’s denial of qualified immunity, absolute (quasi-judicial) immunity, and immunity under two California statutes. The court concluded that it has jurisdiction over defendants’ appeals from denial of state-law immunity because the district court’s denial determined rights collateral to those asserted in the action, and like the denial of qualified immunity, the district court’s decision is effectively unreviewable on appeal from a final judgment; LA County and LASD may only appeal denial of state-law statutory immunity; and Baca, in his individual capacity, may appeal denial of qualified immunity and of quasi-judicial immunity. The court also concluded that plaintiff has sufficiently pleaded a Fourteenth Amendment violation and he is not entitled to qualified immunity where, at the time of plaintiff's incarceration, the standards for determining whether alleged police conduct violates the Fourteenth Amendment were clearly established. In this case, although plaintiff’s arrest for driving under the influence was valid, the warrant on which he was later held matched only his first and last name and date of birth; plaintiff is nine inches taller and forty pounds heavier than the warrant subject; and, even a cursory comparison of plaintiff to the warrant subject should have led officers to question whether the person described in the warrant was plaintiff. Finally, because the facts plaintiff alleged go beyond the limits of quasi-judicial immunity, this immunity does not apply to Baca. Accordingly, the court affirmed the judgment. View "Garcia v. Cnty. of Riverside" on Justia Law