United States District Court, D. New Mexico
MEMORANDUM OPINION AND ORDER GRANTING DEFENDANTS'
MOTION FOR SUMMARY JUDGMENT
STEPHAN M. VIDMAR United States Magistrate Judge
MATTER is before the Court on Defendants Lt. Arturo Salinas
and Lea County Detention Facility (“LCDF”)'s
Motion for Summary Judgment, [Doc. 15], [Doc. 16],
filed on January 16, 2019. Plaintiff responded on January 30,
2019. [Doc. 17]. Defendants replied on February 7, 2019.
[Doc. 18]. The parties consented to have the undersigned
conduct dispositive proceedings in this matter. [Doc. 14].
The Court held oral argument on the Motion on February 28,
2019. [Doc. 21] (Clerk's Minutes). The Court has
considered the briefing, oral argument, the relevant portions
of the record, and the relevant law. Being otherwise fully
advised in the premises, the Court will
GRANT Defendants' Motion.
February 21, 2018, the District Attorney's Office in Lea
County, New Mexico, filed a petition to revoke Plaintiff
Shannon Jeter's probation on the grounds that he had
violated conditions of probation. [Doc. 16] at 16. Jeter was
arrested and processed into the Lea County Detention Facility
on March 29, 2018. Id. at 17-19. On May 14, 2018,
the Honorable Mark Sanchez, District Judge in New Mexico
state court, held a probation violation hearing. Id.
at 20. Plaintiff, his Public Defender, and a District
Attorney attended the hearing. Id. Judge Sanchez
found that Plaintiff had violated his probation and ordered
him incarcerated. Id. Upon his return to LCDF,
Plaintiff told Salinas-an officer at LCDF-that the detention
facility should release him immediately because he had
sufficient confinement credit to satisfy his sentence in
full. [Doc. 17] at 2; [Doc. 17-1] at 1. Through June 12,
2018, he continued to complain to Salinas that he should be
released. [Doc. 17-1] at 1. At one point, when viewing
Plaintiff's paperwork, Salinas said, “Oh shit,
you're right, we could get in trouble for this.”
12, 2018, Judge Sanchez issued an Order Revoking Probation
and Commitment to the Lea County Detention Center (the
“Order”). [Doc. 16] at 21. The Order did not
provide a certain release date. Rather, Judge Sanchez ordered
Plaintiff confined to the LCDF for 364 days, with a
“total” confinement credit of 46 days “as
set forth in the Confinement Credit Attachment.”
Id. at 22. The Confinement Credit Attachment,
however, stated that Plaintiff had 540 days of credit.
Id. at 24. Thus, based on the Attachment, his
confinement credit exceeded his sentence. See Id. at
employee Kristie Parish emailed the District Attorney's
Office on June 13, 2018, asking for “clarification on
the . . . Order.” [Doc. 16] at 26. Receiving no
response, she emailed the District Attorney's Office a
second time on June 27, 2018. Id. at 32. The
District Attorney's Office eventually responded to Parish
by stating that it would prepare an amended order.
Id. No one from LCDF contacted Judge Sanchez's
office seeking clarification of the Order.
Sanchez entered an Amended Order Revoking Probation and
Commitment to the Lea County Detention Center (the
“Amended Order”) on July 2, 2018. Id. at
34. The Amended Order confirmed Plaintiff's confinement
credit and explicitly ordered a release date of July 11,
2018. Id. at 35. Plaintiff was released on July 11,
2018. Id. at 19.
sued LCDF on September 28, 2018. [Doc. 1]. He filed an
Amended Complaint on December 27, 2018, adding Salinas as a
Defendant. [Doc. 9]. In his Amended Complaint, Plaintiff
alleges that Defendants falsely imprisoned him for
approximately one month after his sentence should have
terminated. Id. at 2. He claims that Defendants are
liable for his false imprisonment (1) under the Fourth
Amendment pursuant to 42 U.S.C. § 1983, and (2) under
New Mexico law. Id. at 3-4. Plaintiff claims that
LCDF is liable for his false imprisonment due to its failure
to train and supervise its officers “regarding how to
read a confinement order to determine whether the sentence
had already been served in full.” Id. at 3.
Defendants filed their Motion for Summary Judgment on January
16, 2019. [Doc. 16].
STANDARD OF REVIEW
court shall grant summary judgment if the movant shows that
there is no genuine dispute as to any material fact and the
movant is entitled to judgment as a matter of law.”
Fed.R.Civ.P. 56(a). A court must deny summary judgment if a
reasonable jury could find for the non-movants. Anderson
v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). When
applying this standard, the court must construe the evidence
in the light most favorable to the non-moving parties.
Tolan, 572 U.S. at 657. The party moving for summary
judgment has the initial burden of establishing that there is
an absence of evidence supporting the opposing party's
case. Celotex Corp. v. Catrett, 477 U.S. 317, 323-25
(1986). If the movant meets this burden, the parties opposing
summary judgment must come forward with specific facts,
supported by admissible evidence, which demonstrate the
presence of a genuine issue for trial. Comm. for First
Amendment v. Campbell, 962 F.2d 1517, 1526 n.11 (10th
argue that summary judgment is proper for four reasons.
First, they argue that Salinas is entitled to qualified
immunity because he violated no clearly established
constitutional right when he declined to release Plaintiff
absent a court order. [Doc. 16] at 7-10, 13. Second, they
argue that no false imprisonment occurred because Defendants
released Plaintiff as ordered by the state court.
Id. at 7-10. Third, they argue that neither
Defendant falsely imprisoned Plaintiff under state law for
the same reason. Id. Finally, they contend that all
claims against LCDF must be dismissed because the detention
facility is not a proper party under § 1983 or the
NMTCA. Id. at 5-7.
argues that clearly established law under the Fourth, Eighth,
and Fourteenth Amendments required Defendants to (1)
calculate his release date because the Order lacked a precise
release date, (2) release him upon seeing that his
confinement credits in the Confinement Credit Attachment
exceeded his sentence, and (3) investigate ...