Rivera v. County of Los Angeles

Counties are not liable for violations of federal or state laws when arrestee was mistakenly identified as subject of arrest warrant because the counties had good faith, reasonable beliefs to make arrest, and statutory immunity.

In 1985, a Los Angeles Superior Court issued an arrest warrant for “Santiago Rivera.” In 1989, officers of the Montclair Police Department arrested Santiago Rivera (Rivera). However, fingerprint analysis revealed that the Rivera arrested was not the “Santiago Rivera” sought by the warrant. The municipal court issued Rivera a judicial clearance form and later reissued the warrant but omitted that Rivera had been determined not to be its subject. In 2009, deputies from the San Bernadino Sheriff's Department stopped a car which Rivera was in. Running a routine warrant check, the deputies learned of the 1989 warrant for a “Santiago Rivera” with the same description and date of birth as the Rivera. The deputies arrested Rivera despite his claim of his judicial clearance form because he could not produce it. Rivera remained in custody for one month until staff at the Los Angeles archives found the true subject's fingerprint documents and subsequently released Rivera. Rivera sued Los Angeles and San Bernadino County and each Counties Sheriff’s departments (The Counties) alleging violations of the Fourth and Fourteenth Amendments, violations of state law, and common law false imprisonment. The district court granted the Counties' motions for summary judgment on all of Rivera's claims and Rivera appealed.

The Ninth Circuit affirmed with five holdings. First, the arrest warrant satisfied the Fourth Amendment’s particularity requirement because it contained the subjects name and detailed physical description. Second, even if the Fourth Amendment required The Counties to include more detailed information, Rivera’s § 1983 claim failed because The Counties did not have a policy or custom of failing to do so. Third, the deputies had probable cause to arrest Rivera because they had a good faith, reasonable belief that Rivera was subject of the warrant. Fourth, Rivera’s post-arrest incarceration did not violate his due process rights because the deputies reasonably believed Rivera was the true subject of the warrant and his circumstances did not trigger a duty to investigate further. Finally, The Counties had statutory immunity from Rivera’s state law claims. AFFIRMED