Civil Rights Plaintiffs Obtain Relief

Martinez v. Carson, 2012 WL 4902688 (10/17/12) (N.M.) (Published) - A § 1983 victory involving officers of the Rio Rancho Department of Public Safety (DPS) [a code enforcement branch of the Rio Rancho Police Department]. The officers forced plaintiffs to the ground, handcuffed them and turned them over to the police because the plaintiffs were hanging around outside an apartment building in a high-crime neighborhood. The district court did not allow the plaintiffs to obtain damages for the police officers’ subsequent arrest and detention of the plaintiffs for several hours. The jury found liability and awarded damages for the tackling and handcuffing. The 10th rules the DPS officers were responsible for the natural consequences of their actions, which could include what the police did. A rational jury could find the initial illegal detention was the but-for cause of the further detention, [at least some of it], which was reasonably foreseeable.