## Facts

- Los Angeles County maintained a countywide warrant system (CWS) containing warrants issued by the county’s courts, typically listing a subject’s name, birthdate, address, and physical description; some warrants also included unique identifiers such as fingerprint information, but not all did.
- County policy called for adding an “exoneration” entry to CWS when someone arrested on a warrant was later determined to be the wrong person, and required law enforcement to confirm that a warrant was still active before making an arrest on it.
- In 1985, a Los Angeles County court issued arrest warrant A091945 for “Santiago Rivera” (a person other than plaintiff Santiago Ibarra Rivera) on serious felony charges.
- In 1989, the plaintiff was mistakenly arrested on warrant A091945 and held in county jail for nine days until a fingerprint comparison showed he was not the warrant’s subject; he was released and given clearance paperwork.
- The A091945 warrant was later reissued, but CWS did not contain an exoneration entry reflecting the plaintiff’s 1989 misidentification and clearance.
- In 2009, officers stopped the plaintiff for a vehicle-code violation and ran a records check, which showed warrant A091945 as outstanding.
- The plaintiff told officers the warrant was not for him and stated he had been cleared previously, but he could not locate or produce the clearance paperwork during the stop.
- Officers confirmed the warrant remained active, the warrant subject’s birthdate matched the plaintiff’s exact birthdate, and the plaintiff matched the warrant’s physical description; officers arrested him on the warrant and took him into custody.
- The plaintiff remained detained for about a month while the court and defense counsel attempted to obtain the warrant subject’s fingerprints; once fingerprint records were obtained and compared, the plaintiff was again exonerated as the wrong person.
- The plaintiff sued Los Angeles County (and its sheriff’s department) and San Bernardino County (and its sheriff’s department) under 42 U.S.C. § 1983 and California law, challenging the warrant recordkeeping and the arrest and detention that followed.
- The counties moved for summary judgment.

## Issues

1. Whether the warrant was constitutionally insufficient under the Fourth Amendment because it did not include additional unique identifying information (such as fingerprints) and did not reflect an exoneration entry after the 1989 clearance.
2. Whether the 2009 arrest violated the Fourth Amendment because officers allegedly should have accepted the plaintiff’s claim of mistaken identity despite the warrant match and confirmation that the warrant was active.
3. Whether the approximately month-long detention pending fingerprint verification violated the Fourteenth Amendment’s Due Process Clause.
4. Whether the plaintiff produced evidence of a municipal policy, custom, or practice that caused a constitutional violation, as required for liability under *Monell*.
5. Whether California statutory immunities defeated the plaintiff’s state-law claims, including under the Bane Act and for false imprisonment.

## Decision

- The court granted summary judgment for all defendants on all claims.
- The court concluded the warrant satisfied the Fourth Amendment’s particularity requirement based on the identifying information it contained (including name and physical description), even though it did not include fingerprint identifiers.
- The court held the 2009 arrest was objectively reasonable because officers relied on a facially valid, active warrant and the plaintiff’s name, exact birthdate, and appearance matched the warrant information.
- The court found the plaintiff’s month-long detention did not establish a due process violation on the record presented, where authorities were attempting to confirm identity through fingerprint comparison and delays were tied to obtaining fingerprint records.
- The court ruled the plaintiff failed to establish a triable issue that any county policy, custom, or practice was the moving force behind a constitutional violation, defeating *Monell* liability.
- The court entered judgment for the counties on the state-law claims because applicable statutory immunities available to employees also protected the public entities from derivative liability.

## Legal Principles

- A warrant meets the Fourth Amendment particularity requirement if it identifies the person to be seized with sufficient descriptive information; the Constitution does not require inclusion of every available unique identifier.
- An arrest based on a facially valid warrant is generally reasonable when officers confirm the warrant is active and the arrestee’s identifying information matches the warrant, even if the arrestee claims mistaken identity without corroborating documentation.
- A mistaken-identity detention does not violate due process solely because it is lengthy; the analysis turns on the nature of the procedures used and the level of fault shown by officials in resolving the identity dispute.
- Municipal liability under § 1983 cannot be based on respondeat superior; a plaintiff must show a policy, custom, or act of a final policymaker that caused the constitutional injury.
- Under California law, when public employees are protected by statutory immunities for conduct within the scope of their duties, related state-law claims against the public entity may also fail.

## Conclusion

The court granted summary judgment because the warrant was sufficiently descriptive under the Fourth Amendment, the 2009 arrest was reasonable given the warrant match and confirmation of active status, the month-long detention while fingerprints were obtained did not amount to a due process violation on the evidentiary record, the plaintiff did not show a county policy or custom causing a constitutional injury under *Monell*, and California statutory immunities barred the related state-law claims.


Rivera v. County of Los Angeles, No. CV 10-1861, 2011 WL 2650006 (2011)