Farm Labor Organizing Committee v. Ohio State Highway Patrol case brief

Farm Labor Organizing Committee v. Ohio State Highway Patrol case brief summary
308 F.3d 523 (2002)

CASE SYNOPSIS

Defendant police officer appealed the judgment of the United States District Court for the Northern District of Ohio at Toledo which determined that he was not entitled to qualified immunity in plaintiff resident aliens' 42 U.S.C.S. § 1983 action.

CASE FACTS
The police officer stopped the resident aliens' vehicle for driving with a faulty headlight. The police officer took their green cards based on his belief that they were forged, and kept them for four days, until the INS verified that the green cards were authentic. In the resident aliens' lawsuit against the police officer contending that their constitutional rights were violated, the police officer contended that he was entitled to qualified immunity.


DISCUSSION

• The district court determined that he was not immune; on appeal, the court affirmed. 
• With regard to the resident aliens' equal protection claim, the police officer was not entitled to summary judgment because the question of whether his allegedly discriminatory motive played a determinative role in his decision to investigate the resident aliens was a factual dispute best suited for resolution at trial. 
• The court held that the police officer's detention of the green cards for four days based upon mere reasonable suspicion was unreasonable, as he could have verified that they were authentic with the INS the day after the seizure.

CONCLUSION

The judgment that the police officer was not entitled to qualified immunity in the resident aliens' civil rights enforcement action was affirmed and the case was remanded.

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