Heck does not bar claims by an overdetained prisoner who “does not challenge the validity of his sentence, [but] merely the execution of his release; no qualified immunity for supervisor who had fair warning that his failure to address rampant overdetention would deny prisoners their immediate or near-immediate release upon conviction; two judges urge en banc review of precedent imposing liability on supervisor.
Clearly established in 2017 that prisoners had Due Process Clause right to timely release from prison; prisoner pled plausible claim against supervisory official who knowingly did not correct mistaken release date.
Inmate’s complaint against Louisiana Department of Public Safety and Corrections Secretary for misclassifying him as sex offender, thereby illegally extending his detention past his release date, sufficiently pled pattern of constitutional violations by untrained employees to establish deliberate indifference for purposes of failure-to-train claim; clearly established in 2018 that Secretary had duty to ensure inmates were timely released.
Person held three days based on mistaken identity on a valid arrest warrant does not have a substantive due process claim for over-detention; case is controlled by Baker v. McCollan, 443 U.S. 137 (1979).
Plaintiff was mistakenly arrested on warrant for another man with same name for second time, and held for three days and nights after officers learned of information that raised significant doubts about his identity; plaintiff’s complaint established deliberate indifference to his Fourteenth Amendment right to be free from overdetention, which requires: (1) the defendant’s subjective knowledge of a risk of serious harm in the form of continued detention even after the plaintiff had a right to be released; (2) disregard of that risk; and (3) disregard by conduct that is more than mere neglig