Carrasca v. Pomeroy

313 F.3d 828 (3d Cir. 2002) ; Clearinghouse Number: 55092

Description

Third Circuit Denies Park Rangers Summary Judgment in Mexican Farmworkers’ Racial Profiling Case

Abstract

The Third Circuit overturned the trial court’s summary judgment for defendants, former New Jersey park rangers, in a racial profiling case brought by four Mexican farmworkers. Plaintiffs were arrested, detained for several hours, and handcuffed to chairs after they were caught swimming in a state park after hours. Defendants also searched and impounded plaintiffs’ car and asked for their green cards. Plaintiffs alleged that one of defendants commented derogatorily on plaintiffs’ ethnicity. During the detention one of the rangers contacted the U.S. Immigration and Naturalization Service several times. None of the white swimmers was arrested. Plaintiffs sued under Section 1983 charging violation of their federal equal protection and Fourth Amendment rights and under state statutes guaranteeing equal protection and barring conspiracy to deprive civil rights. Defendants maintained that plaintiffs swam in underwear or clothing and remained in the lake after repeated instruction to exit and after the other swimmers left the water. These factors and plaintiffs’ failure to produce green cards justified their arrest and detention, defendants claimed. The Third Circuit found material the discrepancies between the parties’ versions of events. The trial court failed to view the evidence in a light most favorable to the plaintiffs, and, when viewed in this light, the evidence was sufficient to survive summary judgment, the Third Circuit found. The Third circuit also rejected the trial court’s holding that the rangers had qualified immunity; it found that questions remained regarding the reasonableness of the rangers’ actions.

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Attorney Information
Docket Date
2002-12-17 00:00:00+00:00

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