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Morales v. Chadbourne
Citations: 235 F. Supp. 3d 388; 2017 WL 354292; 2017 U.S. Dist. LEXIS 11007Docket: C.A. No. 12-301-M-LDA
Court: District Court, D. Rhode Island; January 23, 2017; Federal District Court
Ada Morales, a naturalized U.S. citizen born in Guatemala, was unlawfully detained at a state prison based on an Immigration and Customs Enforcement (ICE) detainer, which was issued solely due to her Hispanic surname and Guatemalan origin. This 24-hour detention raised significant constitutional concerns, highlighting systemic failures at both state and federal levels. The court emphasized the danger of granting ICE unchecked discretion to detain American citizens without accountability, which undermines due process rights. ICE is responsible for enforcing immigration laws and issues detainers based on its investigations or information from state and local authorities. The Rhode Island Department of Corrections (RIDOC) routinely honored ICE detainers without verifying the underlying facts. In Morales’ case, she was arrested on state charges and processed at the RIDOC, where she provided personal information, including her citizenship status, but the citizenship field in the inmate database was left blank. Despite her assertion of citizenship, her information was not adequately recorded, leading to her wrongful detention. The case illustrates the failures in the collaboration between ICE and state law enforcement, as both parties shifted blame while neglecting their responsibilities to prevent the wrongful detention of a U.S. citizen. Agent Donaghy conducted an initial citizenship search on Ms. Morales using the INFACTS database, which returned a blank citizenship field. He subsequently checked two additional federal databases, CIS and NCIC, but found no results for 'Ada Morales.' Despite this, he issued a detainer based on Ms. Morales' married name and her birth in Guatemala, asserting probable cause for her removal from the U.S. The detainer was faxed to the Rhode Island Department of Corrections (RIDOC), which was instructed to hold Ms. Morales for up to 48 hours for federal custody. Upon her appearance in Rhode Island Superior Court, the state court withdrew the warrant for state charges and released her on personal recognizance, while informing her of an immigration hold requiring her to report to the Attorney General’s office for processing, including fingerprinting. Despite her husband's presence with her U.S. passport, no officials from ICE were present. Ms. Morales remained in custody solely due to the ICE detainer, during which time she faced threats and harassment from RIDOC staff, describing her time in custody as traumatic. On May 5, 2009, ICE agents confirmed her citizenship and released her. Ms. Morales filed a lawsuit in 2012 against Agent Donaghy, Boston Field Office Director Bruce Chadbourne, the United States, RIDOC Director A.T. Wall, and two correctional officers, claiming violations of her rights. The defendants sought to dismiss the case, with federal defendants claiming qualified immunity. The court denied the motions in Morales v. Chadbourne, 996 F.Supp.2d 19 (D.R.I. 2014), and the First Circuit affirmed the decision in Morales v. Chadbourne, 793 F.3d 208 (1st Cir. 2015). The case has now progressed to cross motions for summary judgment after discovery. On a motion for summary judgment, the moving party must demonstrate the absence of genuine disputes regarding material facts and entitlement to judgment as a matter of law. If successful, the nonmoving party can only counter by presenting specific facts that establish a genuine issue for trial, supported by evidence compelling enough for a reasonable jury to rule in their favor. The court's role is not to weigh evidence but to ascertain whether a genuine issue exists, favoring the non-moving party in its consideration of facts and reasonable inferences. Summary judgment relies on the presence of evidence, not on pleading adequacy. When evaluating cross-motions, the standard remains unchanged, with each motion assessed separately. In the claims against the federal defendants, Ms. Morales alleges violations of her Fourth Amendment rights against Agent Donaghy and ICE Field Office Director Chadbourne, along with negligence and false imprisonment claims against the United States under the Federal Tort Claims Act. She seeks summary judgment, asserting she was unreasonably detained without probable cause. The defendants object and cross-move for summary judgment, reasserting a defense of qualified immunity. Federal law grants immigration officers authority to detain and interrogate individuals suspected of immigration violations without a warrant, but such actions must still comply with Fourth Amendment protections against unreasonable seizures. The First Circuit affirms that immigration stops and arrests must meet the same standards of reasonable suspicion for brief stops and probable cause for further actions. Agent Donaghy required probable cause to issue a detainer for Ms. Morales, as her detention extended beyond a brief stop. In 2009, an immigration officer needed probable cause to arrest and detain individuals for immigration status investigations. Although the First Circuit did not determine whether Agent Donaghy had probable cause, it acknowledged that this Court is now positioned to evaluate that issue based on undisputed facts. The Court's primary focus is whether Agent Donaghy had probable cause under the Fourth Amendment. Probable cause exists when an officer, using trustworthy information, reasonably believes a crime has occurred or is imminent, and that the individual likely committed it. Agent Donaghy's issuance of the ICE detainer was based on one confirmed fact—Ms. Morales's Guatemalan birth—and two inferences from missing information: a blank citizenship field in the INFACTS database and her absence from the CIS and NCIC databases. The Court will assess whether these elements collectively supported a finding of probable cause. Regarding foreign birth, it has been established that it cannot alone justify detention. Agent Donaghy acknowledged that issuing a detainer solely based on a person's foreign birth would be constitutionally improper, thus invalidating any argument that Ms. Morales’s birthplace was sufficient for probable cause. Concerning the blank citizenship field in the INFACTS database, Agent Donaghy claimed it, alongside her Guatemalan birth, indicated probable cause. However, the blank field provided no information about Ms. Morales's citizenship status and could not be deemed trustworthy evidence. Agent Donaghy did not inquire with RIDOC about the blank citizenship status, and ICE did not expect local law enforcement to determine citizenship at intake. Consequently, relying on this blank field for probable cause was deemed unreasonable. Agent Donaghy queried the CIS and NCIC databases using Ms. Morales’ name and date of birth, but no records appeared, which he believed indicated a lack of probable cause for the detainer. However, he was unaware of whether the CIS database was complete. Discovery established that agents were informed in 2009 that CIS is incomplete and may not include all aliens. Thus, the absence of a record in such a database cannot substantiate probable cause. Notably, Agent Donaghy failed to search CIS using Ms. Morales' social security number, a unique identifier recommended by ICE for thorough searches. Additionally, he only searched using her married name, "Ada Morales," despite knowing that women often change their names upon marriage, which could lead to incomplete results. The court concluded that Agent Donaghy's failure to conduct a comprehensive search and reliance on incomplete databases did not provide probable cause for the detainer, violating Ms. Morales’ Fourth Amendment rights. Regarding proximate cause, Agent Donaghy contended that he was not responsible for Ms. Morales’ detention since RIDOC, not ICE, held her. However, under § 1983, causation follows common-law tort principles, establishing that an officer can be liable for actions that set in motion a series of events leading to constitutional violations. The court determined that without Agent Donaghy’s issuance of the detainer, Ms. Morales would have been free to leave post-arraignment. The detainer explicitly instructed RIDOC to hold her for up to 48 hours, and Donaghy, knowing RIDOC typically complied with ICE detainers, was found to be a proximate cause of her unconstitutional detention. Agent Donaghy's assertion of qualified immunity hinges on his claim that he reasonably believed his actions complied with the law when he issued the detainer without probable cause, which the Court had previously found to be a proximate cause of Ms. Morales' unconstitutional loss of liberty. Qualified immunity protects officers from personal liability if they reasonably believe their conduct is lawful. To evaluate this defense, the Court must assess whether the facts allege a constitutional violation and whether that right was clearly established at the time. The analysis involves determining if a reasonable officer would have recognized the conduct as violating established rights. Importantly, qualified immunity is not contingent on the existence of a case directly on point, but rather on whether the unlawfulness of the actions was apparent based on pre-existing law. The Court notes that even without a precedent, officials may still be aware that their actions violate established law in novel situations. Recent Supreme Court rulings reinforce that general legal principles can provide sufficient warning to officers about potential unlawful conduct, emphasizing that the clarity of the law is assessed in the context of established norms. Agent Donaghy lacked probable cause to issue a detainer for Ms. Morales, as the evidence did not reasonably indicate she had committed a crime. For qualified immunity to apply, Donaghy must demonstrate that the unlawfulness of his actions was not apparent to a reasonable officer in his position. He argues that in 2009, there were no cases establishing that an officer could not rely on an incomplete electronic database after a fruitless search. Donaghy attributes his reliance on the database, INFACTS, to its shortcomings and the state officers who maintained it. However, the court finds that it was not reasonable for Donaghy to conclude that Ms. Morales was not a citizen based solely on a blank citizenship field in the database. Furthermore, he acknowledged that the CIS database was incomplete and had the potential for inaccuracies, especially regarding her citizenship status linked to her maiden name. His failure to search for Ms. Morales using her social security number, which ICE expected agents to do, further undermines his claim of reasonable reliance. The court asserts that by 2009, it was clearly established that an ICE officer must have probable cause to issue a detainer and conduct a thorough investigation. Donaghy's issuance of the detainer without probable cause and following an insufficient search was deemed unconstitutional. The cases he referenced to support his claim for qualified immunity were found unpersuasive, as they involved reliance on incorrect rather than incomplete information. A database search's validity is contingent on the completeness of the information and the thoroughness of the search based on available identifiers. Agent Donaghy issued 77 detainers in 2009, of which 31 were cancelled and only 2 resulted in ICE custody, indicating a nearly 50% error rate. Director Chadbourne explained that cancelled detainers often involved U.S. citizens or lawful permanent residents, thereby reflecting the unlawfulness of Agent Donaghy's actions, which would have been clear to a reasonable officer. Consequently, Agent Donaghy is denied qualified immunity, and Ms. Morales' Motion for Summary Judgment against him is granted. Bruce Chadbourne, as the Director of ICE's Boston Field Office, had supervisory responsibilities over enforcement actions and was tasked with ensuring compliance with national policies, including those outlined in the 2008 Hayes Memo. This memo mandated that agents require probable cause before issuing detainers and directed immediate investigations into claims of citizenship. Ms. Morales argues that Chadbourne violated her Fourth Amendment rights by failing to provide adequate supervision and training to prevent improper detainer issuance. Chadbourne contends he was not responsible for training or policy establishment, claiming these duties were handled at the ICE training academy and headquarters. The court evaluates Chadbourne's supervisory liability, noting that a supervisor can be held accountable for constitutional violations if a direct link between a subordinate's actions and the supervisor's inaction or misconduct is established. Evidence suggests that Chadbourne did not adequately train or supervise Agent Donaghy regarding detainer issuance. Director Chadbourne acknowledged his responsibility for communicating ICE policy but failed to recall discussing or training his agents on the detainer form. He did not review the Hayes Memo with them and was unaware that probable cause was necessary to issue a detainer, mistakenly believing that an agent need not confirm a person's illegal status prior to issuing one. This lack of supervision allowed Agent Donaghy to issue a detainer against Ms. Morales without probable cause, based on incomplete information, and without further inquiry. Additionally, Chadbourne did not analyze or report detainer statistics as required by a 2007 ICE policy, which revealed that agents in the Boston Field Office canceled approximately two detainers for every three issued. Chadbourne attributed detainer cancellations solely to individuals being legally present in the U.S., indicating his ignorance of potential issues within his office's processes. The Court concluded that there was a direct link between Donaghy's unconstitutional actions and Chadbourne’s failure to train and supervise his agents, establishing Chadbourne's liability for the unlawful detainer due to his deliberate indifference to the legal standards governing detainers. Chadbourne also claimed qualified immunity, which requires proving that the constitutional right was not clearly established and that he, as a reasonable officer, did not recognize his conduct as violative of that right. His defense failed on the clearly established prong, as it was evident in 2009 that Ms. Morales had a constitutional right against detainers lacking probable cause, and Chadbourne should have recognized that his actions violated the Fourth Amendment. He was deliberately indifferent to the requisite probable cause standard for issuing detainers. The Hayes Memo outlined mandatory directives that Director Chadbourne was responsible for knowing, communicating, and supervising among his agents, particularly regarding the enforcement of immigration detainers. He failed to maintain required statistics, resulting in violations of constitutional rights, specifically affecting Ms. Morales. The Court found his actions in 2009 were not objectively reasonable, denying him qualified immunity. Consequently, Ms. Morales' Motion for Summary Judgment against Director Chadbourne was granted, while his own motion was denied. Ms. Morales also brought claims of negligence and false imprisonment against the United States under the Federal Tort Claims Act (FTCA), which allows suits against the government for torts caused by wrongful acts of employees acting within their official capacity. While the FTCA generally exempts intentional torts, it permits claims for false imprisonment arising from law enforcement actions. Ms. Morales argues that both Agent Donaghy and Director Chadbourne committed torts against her for which the United States is liable. The United States countered with a motion for summary judgment, claiming its agents did not violate her rights and that her detention was caused by state actors after a judge discharged her. To establish her false imprisonment claim under Rhode Island law, Ms. Morales must prove four elements, including lack of legal justification for her confinement. For her negligence claim, she must demonstrate a duty owed by the defendant, a breach of that duty, causation, and actual damages. The United States' argument against liability was rejected due to the Court's prior finding that Agent Donaghy and Director Chadbourne did violate her rights, thereby undermining their defense that the state’s actions were solely responsible for her detention. No U.S. employee physically detained Ms. Morales after her state court arraignment until RIDOC handed her over the next morning. The defense's argument fails because the U.S. cannot claim RIDOC caused Agent Donaghy to issue the detainer while simultaneously conceding RIDOC lacks authority over immigration matters. ICE cannot fault RIDOC for not thoroughly interviewing Ms. Morales about her immigration status, as that responsibility does not fall on the state. Although RIDOC did not gather all necessary immigration information at intake, Agent Donaghy incorrectly assumed Ms. Morales was not a citizen based on a blank field in the INFACTS system, without seeking clarification from RIDOC or using her social security number to verify her citizenship status. The expectation that RIDOC would physically detain Ms. Morales does not absolve Agent Donaghy of responsibility; his actions directly resulted in her detention for up to 48 hours as directed by the detainer. The U.S. is liable to Ms. Morales under the Federal Tort Claims Act (FTCA), leading to the denial of the United States’ Motion for Summary Judgment and the granting of Ms. Morales’ Motion for Summary Judgment. The court also found the United States, Agent Donaghy, and Director Chadbourne liable for violating Ms. Morales’ constitutional rights, granting Director Wall’s Cross Motion for Summary Judgment against the United States. Additionally, Ms. Morales has four counts against RIDOC Director Wall for unlawful confinement, including violations of her constitutional rights and state law claims of false imprisonment and negligence. Director Wall's motion to dismiss these counts was denied, and he has now moved for summary judgment, asserting for the first time a claim of qualified immunity, to which Ms. Morales has cross-moved for summary judgment against him. The Court determined that Ms. Morales presented a valid claim of constitutional violations, specifically illegal seizure, as she was detained based solely on an invalid request linked to her country of birth. The Court also found a procedural due process violation because the Rhode Island Department of Corrections (RIDOC) failed to allow Ms. Morales to provide proof of her citizenship, despite her assertions of being a U.S. citizen. This failure to grant notice and an opportunity for a hearing constituted a violation of her rights. Regarding qualified immunity for Director Wall, the Court is tasked with assessing whether his actions in Ms. Morales’ detention were shielded by this defense, which he raised for the first time in his summary judgment motion. The Court follows a two-part analysis: determining if a constitutional right was violated and if that right was "clearly established" at the time. The analysis requires a factual examination based on the specific circumstances of the case. Ms. Morales argues that her right to be free from unconstitutional seizure was clearly established in 2009. However, the Supreme Court has advised against broadly defining clearly established law, suggesting a need for specificity in evaluating the nature of the conduct in question. The court evaluates whether Director Wall is entitled to qualified immunity regarding Ms. Morales' Fourth Amendment seizure claims, focusing on the context of May 2009. It emphasizes that qualified immunity applies if a reasonable corrections director would not have recognized a constitutional violation in honoring an ICE detainer. The court notes that Ms. Morales concedes RIDOC officials are not required to make citizenship determinations, contradicting her assertion that Wall should have independently assessed her status during her detention. Although current law clarifies that RIDOC was not obligated to detain Morales under the ICE detainer, this was not firmly established in 2009, suggesting Wall's actions were not unreasonable at that time. The legal landscape regarding ICE detainers shifted post-2014, but in 2009, it was reasonable for state officials to assume that ICE's detainer was based on probable cause. Wall believed that honoring ICE detainers was lawful, a view supported by the prevailing practice among New England law enforcement before 2009, which typically did not involve independent assessments of probable cause. Director Wall and the Rhode Island Department of Corrections (RIDOC) are found to have reasonably concluded in 2009 that the ICE detainer was valid, supported by probable cause, and mandatory. This reasonable but mistaken belief does not result in personal liability for Director Wall, who is granted qualified immunity. In evaluating the procedural due process claim, the Court focuses on whether a reasonable defendant would have known their conduct violated constitutional rights. The Court determines that Director Wall would not have understood his actions as a violation, as RIDOC had no role in ICE’s detainer practices beyond holding the individual and notifying ICE. There is a lack of evidence that RIDOC rejected attempts to provide evidence of citizenship, despite claims from Ms. Morales regarding her husband's presence in court with documentation. Additionally, regarding the state law tort claims of false imprisonment and negligence asserted by Ms. Morales, the Court notes that for a false imprisonment claim, there must be intent to confine, awareness of confinement by the individual, lack of consent, and absence of legal justification. The analysis of these claims will be handled concurrently due to the similarity of arguments presented by both parties. To establish a negligence claim, Ms. Morales must demonstrate a legally recognizable duty, a breach of that duty, proximate causation of injury, and damages. The court ruled that Ms. Morales failed to provide sufficient evidence that Director Wall acted without legal justification, leading to the dismissal of her false imprisonment and negligence claims against him. Consequently, Director Wall's motion for summary judgment on both constitutional and state law tort claims was granted, while Ms. Morales' motion for summary judgment was denied. The court expressed concern over the wrongful detention of a U.S. citizen based on an erroneous immigration detainer, emphasizing the need for law enforcement to implement constitutional policies to prevent such errors. Additionally, Ms. Morales' motion for summary judgment against Federal Defendants Bruce Chadbourne, Edward Donaghy, and the United States was granted, while their motion for summary judgment was denied. The detainer issued by ICE is a request for state law enforcement to hold individuals for up to 48 hours for immigration status investigation. The Mayor of Providence has committed to not holding individuals charged with civil infractions for federal immigration officials. Testimony from ICE officials indicated that local law enforcement had no obligation to verify the validity of ICE detainers. Following the case's progression, Rhode Island's Governor issued a policy regarding the enforcement of federal immigration detainers. RIDOC will only honor immigration detainers with a judicial order of deportation or removal. ICE agents can access daily commitment reports via INFACTS, detailing individuals in RIDOC custody. The CIS database, maintained by the Department of Homeland Security, tracks individuals subject to immigration laws, while NCIC, managed by the FBI, contains criminal history information. Prior to the lawsuit, ICE issued an unsubstantiated detainer for Ms. Morales, which was not reflected in her immigration file or any federal database, despite her citizenship. The Court dismissed claims against Gregory Mercurio and Ms. Morales voluntarily dismissed claims against David Riccio. Ms. Morales has claimed punitive damages against Agent Donaghy, arguing that a jury should determine the appropriateness of such damages. Agent Donaghy has moved for summary judgment, asserting insufficient evidence for punitive damages, but the Court has denied this motion without prejudice, allowing for future motions. The Bayes Memo from 2008 outlines ICE policy on detainers. The Court's decision on punitive damages for Director Chadbourne reflects its ruling on Agent Donaghy's motion. RIDOC Director Wall has filed a cross-claim against the United States, also moving for summary judgment. The FTCA applies Rhode Island law to determine tort elements, as the events occurred in Rhode Island. The United States contends that Ms. Morales' detention could have been minimized or prevented if the Rhode Island Department of Corrections (RIDOC) had notified ICE about her custody before ICE's office closed. The record indicates that Ms. Morales was transported back to the Adult Correctional Institutions (ACI) in the late afternoon, with RIDOC faxing ICE at 8:28 p.m. to inform them of her detainer and requesting a pickup the following day. The United States claims an earlier notification would have led to an immediate investigation, thus preventing her extended stay in state custody. However, this assertion is deemed speculative and improperly shifts responsibility to the State. RIDOC's internal policy mandated inquiry into inmates' citizenship, as testified by Officer Lyons, but this was not driven by an immigration-specific policy; rather, it was part of a broader demographic data collection initiative. The Court refrains from detailing specific undisputed facts, opting to focus on the State's immunity from the claims in subsequent analysis. The Court questions whether the State was obligated in 2009 to hold a formal hearing regarding citizenship, given its limited role in immigration matters, but concludes that it is necessary to address the State's qualified immunity defense. Additionally, in response to erroneous detainers issued by ICE that led to the detention of U.S. citizens, some state law enforcement agencies began implementing policies from 2010 to 2012 concerning the enforcement of ICE detainers.