Martinez v. Santiago

Dist. Ct. did not err in granting defendants-jail probation officers’ motion for summary judgment in plaintiff-pretrial detainee’s section 1983 action, alleging that defendants violated his due process rights by authorizing his continued detention for period of four days after they were either aware or should have been aware that he was not person identified in 2015 arrest warrant that formed basis of his detention. Record showed that plaintiff’s brother had lied to police in 2015 and identified himself by giving them name and birth date of his brother (plaintiff), and 2015 arrest warrant was subsequently issued in plaintiff’s name when his brother failed to report for probation. Plaintiff was subsequently arrested on unrelated offense, but was held on 2015 arrest warrant. On next day, plaintiff’s girlfriend told defendants that they had wrong person in custody, that plaintiff’s brother was actual person subject to warrant, and that plaintiff was on parole in Pennsylvania at time of issuance of 2015 arrest warrant in Wisconsin. While defendants did not release plaintiff until 4 days later, plaintiff failed to show any due process violation, where: (1) defendants took steps to investigate girlfriend’s claim, and (2) plaintiff failed to show that defendants ignored evidence, and defendants otherwise could properly take steps to verify girlfriend’s information. Fact that defendants might have been negligent in delaying confirmation that plaintiff was wrong person in custody was insufficient to establish due process claim.