APPEAL FROM THE IOWA DISTRICT COURT FOR STORY COUNTY THE HONORABLE WAUGHIN JARTH, JUDGE

Abstract

Legal Brief. 52 pages2025 Supreme Court Competition Problem: Dale Gilbert is an ordinary graduate student, except he is one of four identical quadruplets. One of his brothers, TBD Gilbert, was the subject of an arrest warrant. Dale was arrested on that warrant by a Story County deputy who thought that "TBD" was an alias or a placeholder. The deputy confirmed that Dale's last name and birth date matched the warrant, so he arrested Dale and took him to the Story County Jail. That was around 4:45 p.m. on Friday, December 22. As soon as Dale figured out that they were looking for "TBD Gilbert," he told every deputy within earshot that he was not TBD and that he could prove that TBD Gilbert was a separate person. The four of them used to be in a boy band called 2winz, and their last music video opened with a graphic of each brother's name. That music video was the top search engine result for 2winz (and it still is — seriously, go look). Dale repeatedly asked the deputies who monitored the jail to take a few seconds to access the publicly available proof that Dale Gilbert and TBD Gilbert were two separate people. None of the deputies would do it; they told him that he could say what he needed to say during his appearance before the next available magistrate, as was standard procedure. No magistrates were available over the weekend or on Christmas day. Dale stayed in jail until the morning of December 26, when he had his virtual appearance before the magistrate who issued TBD's arrest warrant. The judge immediately knew that Dale was not TBD. He ordered the Story County deputies to release Dale and apologize for ruining his holiday weekend. Dale sued Story County, alleging that the deputies violated his constitutional rights. He has two claims. His first alleges that they violated his Fourth Amendment right to be free from unreasonable seizures. He argues that, even if the arrest was a reasonable mistake of fact, it stopped being reasonable as he repeatedly told them that he was not TBD and offered readily available proof. It's not clear where this Court should draw the line between a reasonable seizure that arises from ordinary execution of an arrest warrant in good faith, and an unreasonable seizure that even a valid arrest warrant can't salvage. How should a court tell the difference? Dale's second claim alleges that the deputies violated his Fourteenth Amendment guarantee against deprivations of liberty without due process. The U.S. Supreme Court said that a three-day stint in jail in a similar case of mistaken identity didn't establish a due process violation, in Baker v. McCollan. How should this Court apply Baker? And Baker was decided in 1979 — have subsequent cases (or other developments) changed how courts should apply Baker in cases like these? It's up to our intrepid student advocates to try to guide the Court to satisfying answers to those difficult constitutional questions — and they've got just one day to do it