SACRAMENTO, Calif. (CN) — A federal judge found Sacramento County and two government agencies in contempt on Friday in a case of wrongful incarceration, ruling that certain accusations against them can be presented as facts to a jury.
After spending almost two decades in prison after being wrongly convicted on murder and robbery charges, Jeremy Puckett is now trying to get personnel and disciplinary records for his case against the county, sheriff and district attorney’s offices. After filing motions to compel the documents’ production, he sought to hold the agencies in contempt for failing to hand over the records.
On Friday, U.S. District Court Chief Judge Kimberly Mueller agreed in part. She ruled that certain accusations made by Puckett are now considered fact and can be delivered to a jury without dispute, including that the county and sheriff’s office had a practice of refusing to discipline or hold detectives responsible for violating people’s constitutional rights.
Though the judge didn’t grant all of Puckett’s requests, she did also find that one detective in a specific investigation said in court that his practice was to violate people’s constitutional rights.
“I thought it was justice,” said Buzz Frahn, an attorney for Puckett, in a phone interview with Courthouse News. “Judge Mueller found that they had acted willfully.”
“The defendants can’t dispute that or attack it,” Frahn added.
Contacted Friday, the county didn’t provide comment by publication time.
The county had argued that Puckett failed to comply with due process, as he didn’t properly provide any basis for a finding of contempt. The judge disagreed, pointing to a notice in which Puckett specifically told the county that his motion for contempt was based on their failure to obey a magistrate judge’s order for discovery.
That magistrate judge had told the county that, after searching for pertinent records and finding none, it needed to say that and give the judge a chance to determine if the search was adequate.
“The magistrate judge emphasized ‘boilerplate objections do not suffice,’” Mueller wrote.
However, the county offered what Mueller called similarly vague and boilerplate objections when responding to requests for documents — arguments the magistrate judge already had cast aside.
Puckett met his burden to show the county violated the magistrate judge’s order, Mueller ruled. That decision moved the burden to the county to show why it couldn’t comply with the order to present the requested records. In its response, the county didn’t say why it couldn’t obey.
“Defendants belatedly produced documents they had claimed did not exist, for more than a year, and did not explain the steps they took at any point to search for responsive documents either in their responses or amended responses to plaintiff’s requests for production,” Mueller wrote.
That led Mueller to find the county in contempt.
Noting that monetary sanctions haven’t spurred the county to produce the relevant records, Puckett said evidentiary sanctions were needed — that the list of accusations should be deemed true.
The discovery process — obtaining the requested documents — should typically occur without a judge’s supervision, Mueller wrote. Because the county wouldn't cooperate with discovery, Puckett asked the judge to intervene, prompting the county to respond by asking the magistrate judge to reconsider seven times.
“Moreover, defendants have misled the court and plaintiff, in material respects,” Mueller wrote. “For over a year, defendants claimed not to have the documents they did belatedly produce and repeatedly represented to the magistrate judge they did not have the documents.”
Subscribe to Closing Arguments
Sign up for new weekly newsletter Closing Arguments to get the latest about ongoing trials, major litigation and hot cases and rulings in courthouses around the U.S. and the world.
Additional Reads
-
Exodus of disabled students? August 30, 2024 -
In Texas, a court is born August 30, 2024