Rivera v. County of Los Angeles

Santiago Rivera (S.R.) (plaintiff) brought an action against Los Angeles County (the county) (defendant) under 42 U.S.C. § 1983 based on the following facts. The county maintained a countywide warrant system (CWS) that included all the warrants issued by the county’s courts. Any warrant contained a variety of information, including the subject’s name, birthdate, address, and physical description. Warrants could but did not always include unique identifiers, such as fingerprint information. The county’s policy was to update CWS with an “exoneration” entry to indicate that an individual who had been arrested on a warrant was later determined to be the wrong person. Law-enforcement personnel were also required as a matter of policy to confirm that a warrant was still active prior to making an arrest. In 1985, a county court issued an arrest warrant (A091945) for “Santiago Rivera”—not S.R.—on serious felony charges. In 1989, S.R. was mistakenly arrested on the warrant. S.R. was released from a county jail nine days later after a fingerprint comparison showed that S.R. was not the subject of the warrant. S.R. received clearance paperwork. The A091945 warrant was reissued but did not include an exoneration entry. In 2009, S.R. was stopped by officers for a vehicle-code violation. A records check showed that the A091945 warrant was outstanding. S.R. asserted that the warrant was not for him, but he could not find his clearance paperwork. The officers confirmed that the warrant was still active, the subject’s birthdate was S.R.’s exact birthdate, and S.R. matched the physical description. S.R. was arrested and taken into custody. For various reasons, including the court and public defender’s inability to obtain a copy of the subject’s fingerprints, S.R. was detained for a month until he was finally exonerated through a fingerprint comparison. Following the second incident, S.R. claimed that his constitutional due-process rights had been violated. The county filed a motion for summary judgment.