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Case Name Estrada v. Rhode Island IM-RI-0002
Docket / Court 1:07-cv-00010 ( D.R.I. )
State/Territory Rhode Island
Case Type(s) Immigration
Attorney Organization ACLU National (all projects)
Case Summary
The lawsuit touches on the national controversy over whether local police should be involved in enforcement of federal immigration laws.

On January 8, 2007, the ACLU of Rhode Island filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for Rhode Island against the Rhode ... read more >
The lawsuit touches on the national controversy over whether local police should be involved in enforcement of federal immigration laws.

On January 8, 2007, the ACLU of Rhode Island filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for Rhode Island against the Rhode Island State Police, alleging that its officers engaged in racial profiling when they stopped and detained 14 Guatemalans in a van on Interstate 95 and transferred them to immigration officials. The lawsuit alleged that a State Police officer pulled over the van because the driver failed to use his turn signal when changing lanes. After the officer confirmed that the driver's license and registration were valid and that he had no outstanding warrants, he demanded that the passengers produce documents "demonstrating their U.S. citizenship." When none of the occupants could produce citizenship papers, they were escorted to the federal Office of Immigration and Customs Enforcement in Providence.

Plaintiffs claimed that the defendants' conduct violated their rights to be free from discrimination and from unreasonable searches and seizures as secured by the Fourth and Fourteenth Amendments to the U.S. Constitution, 42 U.S.C. § 1981, the Rhode Island Constitution and the Racial Profiling Prevention Act of 2004. The State Police denied all allegations.

After a year of discovery, the State Police filed a motion for summary judgment on May 22, 2008, and the plaintiffs filed a motion for partial summary judgment on the issue of the reasonability of the search on the same day. On December 30, 2008, the District Court (Chief Judge Mary M. Lisi) denied the plaintiffs' motion and granted that of the State Police, finding that the police search was justified by reasonable suspicion under the Fourth Amendment and that the plaintiffs had failed to demonstrate that they had been discriminated against based on race.

The plaintiffs appealed, and on February 4, 2010, a three-judge panel of the First Circuit (Chief Judge Sandra L. Lynch, Judge Juan R. Torruella and Judge Jeffrey R. Howard) affirmed. Estrada v. Rhode Island, 594 F.3d 56 (1st Cir. 2010). In an opinion by Judge Torruella, the panel held that the officer who made the stop was entitled to qualified immunity and thus declined to address the other issues.

The case is now closed.

Christopher Schad - 07/13/2012


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Issues and Causes of Action
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Issues
Constitutional Clause
Equal Protection
Federalism
Unreasonable search and seizure
Defendant-type
Law-enforcement
Discrimination-basis
National origin discrimination
Race discrimination
General
Search policies
Immigration
Constitutional rights
Undocumented immigrants - state and local regulation
Plaintiff Type
Private Plaintiff
Causes of Action State law
42 U.S.C. § 1983
42 U.S.C. § 1981
Defendant(s) Rhode Island State Police
Plaintiff Description 14 Guatemalans stopped on I-95 by the Rhode Island State Police
Indexed Lawyer Organizations ACLU National (all projects)
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 2010
Case Ongoing No
Additional Resources
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Case Studies Threats to the Future of the Immigration Class Action
Washington University Journal of Law and Policy
By: Jill E. Family (Widener University School of Law)
Citation: 27 Wash. U. J.L. & Pol'y 71 (2008)
[ Detail ] [ External Link ]

Docket(s)
1:07-cv-00010-ML-DLM (D.R.I.) 03/01/2010
IM-RI-0002-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
ACLU Files Racial Profiling Lawsuit Against Rhode Island State Police (1/8/2007) 01/08/2007
IM-RI-0002-0001 PDF | Detail
Complaint 01/08/2007
IM-RI-0002-0002 PDF | Detail
Memorandum and Order [Granting Defendants' Motion for Summary Judgment] 12/30/2008 (D.R.I.)
IM-RI-0002-0003 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
[First Circuit] Opinion [Affirming the District Court] 02/04/2010 (594 F.3d 56)
IM-RI-0002-0004 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Lisi, Mary M. (D.R.I.)
IM-RI-0002-0003 | IM-RI-0002-9000
Lynch, Sandra Lea (First Circuit)
IM-RI-0002-0004
Martin, David L. (D.R.I.) [Magistrate]
IM-RI-0002-9000
Torruella, Juan R. (First Circuit, D.P.R.)
IM-RI-0002-0004
Monitors/Masters None on record
Plaintiff's Lawyers Formisano, V. Edward (Rhode Island)
IM-RI-0002-0002 | IM-RI-0002-9000
Defendant's Lawyers Baum, Brenda D. (Rhode Island)
IM-RI-0002-9000
Lee, James R. (Rhode Island)
IM-RI-0002-9000
Moreira, John M. (Rhode Island)
IM-RI-0002-9000
Other Lawyers None on record

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