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The Fourteenth Amendment, U.S. Const. amend. XIV, does not protect against all deprivations of liberty. It protects only against deprivations of liberty accomplished without due process of law. A reasonable division of functions between law enforcement officers, committing magistrates, and judicial officers, all of whom may be potential defendants in a 42 U.S.C.S. § 1983 action, is entirely consistent with due process of law. Given the requirements that arrest be made only on probable cause and that one detained be accorded a speedy trial, a sheriff executing an arrest warrant is not required by the Constitution to investigate independently every claim of innocence, whether the claim is based on mistaken identity or a defense such as lack of requisite intent. Nor is the official charged with maintaining custody of the accused named in the warrant required by the Constitution to perform an error-free investigation of such a claim. The ultimate determination of such claims of innocence is placed in the hands of the judge and the jury.
An individual's brother, using a duplicate of the individual's driver's license which bore the brother's picture, was arrested in Potter County, Texas on narcotics charges, booked in the individual's name and released on bail. Eventually, an arrest warrant intended for the brother was issued for the individual. This individual was later stopped for a traffic violation in another locale, and a routine warrant check revealed that a man bearing his name was wanted in Potter County. Over his protests of mistaken identification, the individual was held in custody for several days before the error was discovered and he was released. He then brought an action against the county sheriff and his surety in the United States District Court for the Northern District of Texas, seeking relief under 42 USCS 1983, which imposed civil liability on any person who, under color of state law, deprived another of rights secured by "the Constitution and laws." The District Court directed a verdict in favor of the sheriff and his surety, but the United States Court of Appeals to the Fifth Circuit reversed, holding that the individual was entitled to have his claim presented to a jury even though the evidence supported no more than a finding of negligence on the sheriff's part.
Did the individual have a claim against the sheriff cognizable under 42 USCS 1983?
The Court held that the individual did not have a claim against the sheriff cognizable under 1983--no attack having been made upon the validity of the arrest warrant--since he failed to satisfy the threshold requirement of 1983 that he be deprived of a right "secured by the Constitution and laws" insofar as he was not deprived of his liberty without due process of law, but rather pursuant to a warrant conforming to the requirements of the Fourth Amendment, the individual's innocence of the charge being largely irrelevant to his claim of deprivation of liberty. Given the requirements that an arrest be made only on probable cause and that one detained be accorded a speedy trial, a sheriff executing an arrest warrant was not required by the Constitution to independently investigate every claim of innocence, whether that claim was based on mistaken identity or a defense such as lack of requisite intent, and an official charged with maintaining custody of the accused named in the warrant was not required by the Constitution to perform on error-free investigation of such a claim. Accordingly, the decision of the appellate court was reversed.