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Jeter v. Lea County Detention Facility

United States District Court, D. New Mexico

March 21, 2019



          STEPHAN M. VIDMAR United States Magistrate Judge

         THIS 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], [1] 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.

         I. BACKGROUND[2]

         On 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.” Id.[3]

         On June 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 22, 24.

         LCDF 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.

         Judge Sanchez entered an Amended Order Revoking Probation and Commitment to the Lea County Detention Center (the “Amended Order”) on July 2, 2018.[4] 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.


         Plaintiff 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.[5] 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].


         “The 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 Cir. 1992).

         IV. ANALYSIS

         Defendants 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.

         Plaintiff 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 ...

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