Myriam Parada v. Anoka County


United States Court of Appeals For the Eighth Circuit ___________________________ No. 21-3082 ___________________________ Myriam Parada Plaintiff - Appellee v. Anoka County; James Stuart, Anoka County Sheriff, All individuals being sued in their individual and official capacity Defendants - Appellants Nikolas Oman, Coon Rapids Police Officer, All individuals being sued in their individual and official capacity; City of Coon Rapids; John Doe, unknown/unnamed defendants, All individuals being sued in their individual and official capacity; Jane Doe, unknown/unnamed defendants, All individuals being sued in their individual and official capacity; Coon Rapids Police Department Defendants ------------------------------ State of Minnesota Amicus on Behalf of Appellee(s) ____________ Appeal from United States District Court for the District of Minnesota ____________ Submitted: March 17, 2022 Filed: November 30, 2022 ____________ Before GRASZ, STRAS, and KOBES, Circuit Judges. ____________ STRAS, Circuit Judge. The Anoka County Jail referred every detainee born outside the United States, including Myriam Parada, to Immigration and Customs Enforcement. The district court1 determined that this policy violates the Equal Protection Clause, and a jury awarded her $30,000 on a false-imprisonment theory. We affirm. I. Parada ended up in the Anoka County Jail after an officer discovered that she had been driving without a license. While going through the booking process, she had to disclose her country of birth, which was Mexico. Even after deeming her “[r]eady for [r]elease,” Anoka County continued to hold her while a deputy contacted Immigration and Customs Enforcement, better known as ICE. The delay was due to Anoka County’s “unwritten policy requiring its employees to contact ICE every time a foreign-born individual is detained, irrespective of whether the person is a U.S. citizen.” (Emphasis added). The way it works is simple: “If the individual [says] they were born abroad, the jail will send ICE a notification” and “attempt[] to wait to start release procedures . . . until [it] hear[s] back,” which “could take between 20 minutes and 6 hours.” Eventually, after four hours of waiting, the deputies released Parada into ICE custody. 1 The Honorable John R. Tunheim, United States District Judge for the District of Minnesota. -2- The delay became the basis for Parada’s federal lawsuit against Anoka County. One of her claims alleged that discriminating against her based on her country of origin violated the Equal Protection Clause. See U.S. Const. amend. XIV, § 1; 42 U.S.C. § 1983. A second was that she was falsely imprisoned. See Kleidon v. Glascock, 10 N.W. 2d 394, 397 (Minn. 1943). Both claims survived summary judgment. The district court concluded that Anoka County’s policy violated the Fourteenth Amendment as a matter of law but left the determination of damages for the jury. The false-imprisonment claim went to the jury on both liability and damages, even though Anoka County filed a pre- verdict motion for judgment as a matter of law. See Fed. R. Civ. P. 50(a). The damages were a mixed bag. The jury awarded her $30,000 for false imprisonment but gave her only one dollar for the constitutional violation. Despite …

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