Reginald Smith v. County of Los Angeles

MEMORANDUM

Sheriff Lee Baca appeals the district court’s denial of qualified immunity on his motion for judgment on the pleadings in this putative class action under 42 U.S.C. § 1983 . Plaintiff Reginald Smith alleges that he has twice been wrongfully arrested on a Los Angeles County Superior Court felony warrant issued for another person with a similar name and physical characteristics, resulting in his incarceration and the denial of his passport application. Smith claims that the Los Angeles County Sheriffs Department’s refusal to update its warrant database with readily available biometric information about warrant subjects and exonerees violates his Fourth and Fourteenth Amendment rights. The only issue before us is whether Baca is entitled to qualified immunity regarding Smith’s Fourteenth Amendment claim based upon alleged violations of his right to international travel. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we reverse.

The district court erred in concluding that the law was clearly established so as to put a reasonable official in Baca’s position on notice that his alleged conduct deprived Smith of the right to international travel without due process…