Mariano Moya, et al. v. Robert Garcia, Sheriff, Santa Fe County, New Mexico, et al.

Petitioners were arrested in Santa Fe County on bench warrants and jailed for 63 and 30 days, respectively, before being given access to a court for arraignment and bail review. On behalf of a class, Petitioners brought this action under 42 U.S.C. § 1983 against their jailers—Santa Fe County, its sheriff, and its wardens—to seek redress for this unlawful deprivation of their liberty. The Tenth Circuit assumed that Petitioners had pleaded a due process violation, but it affirmed the dismissal of the complaint anyway, holding that Respondents “did not cause” any deprivation of Petitioners’ liberty. The Tenth Circuit reached this conclusion by focusing solely on the state court’s delay in scheduling the arraignments, all but ignoring the unlawful detention itself. As the dissent recognized, this approach creates a conflict of authority between the Tenth Circuit and the Fifth, Seventh, Eighth, and Ninth Circuits. The question thus presented is as follows: When a jailer detains a person for an extended period with no access to a court hearing for arraignment and bail review, in violation of his or her Due Process rights, can the jailer avoid liability under § 1983 on the ground that the state court caused the violation because it bears sole responsibility for setting such a hearing?