The opinion of the court was delivered by: Judge Sylvia H. Rambo
This is a civil rights case brought by Plaintiffs Arturo and Modesta Santiago against Defendants York County and John Does 1-10. In their amended complaint, Plaintiffs allege that Defendants violated Plaintiff Arturo Santiago's substantive and procedural due process rights when he was arrested for driving under the influence of alcohol and detained for 47 days based on a warrant lodged by the Baltimore County, Maryland. Defendants filed a motion to dismiss Plaintiffs' amended complaint, which the court converted to a motion for summary judgment. (See Docs. 14, 19.) That motion has been fully briefed and is ripe for disposition.
On April 4, 2009, Plaintiff Arturo Santiago ("Santiago") was arrested and charged in York County with driving under the influence of alcohol ("DUI"). (See Doc. 4-2 at 2 of 37.) Instead of being released on bail after his preliminary hearing, Santiago was detained on outstanding warrants from the District of Columbia and the State of Maryland.
Plaintiffs allege that Santiago immediately informed one of the John Doe Defendants that he had been misidentified and that no warrants were outstanding. The District of Columbia lifted its warrant, but Baltimore County, Maryland refused to do so and Santiago remained incarcerated. As a result of the Maryland warrant, extradition proceedings were scheduled in York County. (Id. at 14 of 37.)
On April 20, 2009, an extradition hearing was held before York County Court of Common Pleas Judge John S. Kennedy. (See id. at 17 of 37.) At this hearing, Judge Kennedy advised Santiago that he had the right to "test the legality of [his] arrest in Pennsylvania on these fugitive warrants, [by] apply[ing] for what is called a writ of habeas corpus and hav[ing] a hearing." (Id. at 21 of 37, lns. 8-12.) Despite being informed of his right to challenge his detention on the Maryland warrant, Santiago waived extradition. (Id. at 26 of 37.) On April 24, 2009, on motion from the Commonwealth of Pennsylvania, Judge Kennedy modified the original order, which adopted Santiago's waiver of extradition, and clarified that the State of Maryland would have "fourteen (14) days following completion of [his] York County sentence" to retrieve Santiago. (Id. at 27 of 37.)
In early May 2009, Santiago pled guilty to the DUI charge, and on May 14, 2009, a guilty plea was scheduled for May 20, 2009. (See id. at 5 of 37.) On May 20, 2009, Santiago appeared with counsel before Judge Gregory Snyder of the York County Court of Common Pleas. At this hearing, Santiago's attorney Robert Balaban, Esquire, informed the court of the duration of Santiago's confinement, and the fact that he was being held on the Maryland warrant. Attorney Balaban requested that the court sentence Santiago to 72 hours to 6 months. (See Doc. 4-2 at 29 of 37.) The transcript reflects a back and forth conversation between Attorney Balaban, Judge Snyder, and the Assistant District Attorney, Duane Ramseur, concerning the proper sentence. (See id. at 29-31 of 37.) Ultimately, the following exchange occurred between Judge Snyder and Santiago:
THE COURT: We understand from the discussion a little bit earlier that instead of the negotiated plea agreement being seventy-two hours to six months plus the other terms, given your circumstances, we would sentence you, if you plead guilty, to time served to six months incarceration. Do you understand this?
[Arturo Santiago]: Yes, sir.
THE COURT: Do you agree to that?
THE COURT: Do you understand that you do not have to ...