Sosav.Martin County, Florida
CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.20-12781
DecidedJanuary 20, 2023
Reporter57 F.4th 1297 (11th Cir. 2023)
JudgesEleventh Circuit panel; see published opinion.
Tags
CivilSection 1983Fourth AmendmentMistaken IdentityOver-DetentionProbable CauseQualified ImmunityRemandRipley's Believe It Or NotIdentity Mix-UpsExtreme Distances & Timelines
Case Summary
Deputies arrested David Sosa on a warrant for another man with the same name and held him for three days before confirming his identity. Sitting en banc, the Eleventh Circuit held that the complaint did not state a Fourteenth Amendment claim for continued detention under the circuit’s governing precedent, because Sosa had been arrested on a valid warrant and held for only three days. It affirmed dismissal of that claim but remanded the remaining issues to the original panel; the opinions sharply disagreed about whether the over-detention should instead be analyzed as an unreasonable seizure.
Opinion
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