Martinez v. Santiago, No. 21-2024 (7th Cir. 2022)
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Rodriguez was arrested for domestic violence. He gave the police his brother’s name and date of birth. He was convicted and sentenced to probation. Although the court had learned Rodriguez’s real name, the judgment of conviction listed “Ely M. Martinez” as an alias for Rodriguez and listed Martinez’s date of birth. Rodriguez failed to report for probation. An arrest warrant was issued with the same information as the judgment. Years later, police arrested Martinez for an unrelated offense and booked him in the Milwaukee County Jail on a Wednesday. The next day, the district attorney decided not to press charges but a warrant check revealed the outstanding warrant for Rodriguez. Although jail officials made efforts to positively identify the detainee, he was not released until Tuesday morning.
Martinez sued under 42 U.S.C. 1983, claiming due process violations. The district court entered summary judgment for the defendants, concluding that Martinez’s detention was relatively brief and Martinez could not show that the defendants failed to investigate or ignored evidence of his innocence. The Seventh Circuit affirmed. Although the defendants could have improved aspects of their investigation, Martinez has not provided evidence showing that they were deliberately indifferent to his claims of mistaken identity.
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