CARON WINS SUMMARY JUDGMENT IN FALSE ARREST CASE

In May 2014, the Ninth Circuit issued an Opinion in favor of Los Angeles County in a false arrest case. Plaintiff was arrested twice (1989 and 2009) on a felony warrant seeking the arrest of another person. After being detained at the Los Angeles County jail on both occasions, he was ultimately exonerated. The only discrepancies between his description and the warrant were a one-inch height difference, a ten-pound weight difference, and a different address. The warrant did not include any numeric or biometric identifiers, nor was it updated after his 1989 arrest to indicate that he had previously been cleared on the warrant. During his 2009 detention, Plaintiff was in custody 33 days. He testified that he complained repeatedly to Sheriff’s Department personnel that he was not the subject of the warrant, but he was not released nor was his identity investigated. Plaintiff brought suit against the County for violation of his Fourth and Fourteenth Amendment rights, claiming the Sheriff’s Department should have (1) updated the warrant information following his 1989 detention; and (2) investigated his identity in response to his claims of mistaken identity during his 2009 detention. The District Court granted summary judgment for the County, and the Ninth Circuit affirmed the judgment in a published opinion, holding that the Fourth Amendment particularity clause does not require an arrest warrant to include numeric or biometric identifiers, so long as it includes sufficient information to identify the warrant subject to the reasonable exclusion of others. The Ninth Circuit further held that Sheriff’s Department personnel were not obligated to investigate Plaintiff’s identity because he reasonably matched the warrant description, and Plaintiff’s due process rights were protected because he was brought to court the day after his arrest and thereafter remained in custody pursuant to the Superior Court’s remanding order.