25. Intake and admissions.

U.S. Appeals Court

PROCEDURES

Golberg v. Hennepin County, 417 F.3d 808 (8th Cir. 2005). A detainee brought a civil rights action against a sheriff and county, alleging that she was subjected to an excessive delay in releasing her from custody. The district court granted summary judgment in favor of the defendants and the detainee appealed. The appeals court affirmed. The detainee had appeared in court in response to a felony fraud charge. The court continued the proceeding but ordered the detainee to be booked at the detention center before her release. When detention center officials discovered that the detainee had two outstanding warrants they required her to post bail before she could be released. As a result, she remained in custody for 32 hours, including ten hours after her father posted the required bail. The court noted that the detainee conceded that the officials had probable cause to detain her after the outstanding warrants were discovered. The appeals court held that the Fourteenth Amendment substantive due process analysis applied to the constitutionality of the delayed release, and that the failure to process the detainee more rapidly did not rise to the level of deliberate indifference. The court found that a sign advising detainees that completing their paperwork might take "more than eight hours" did not show reckless disregard. The...