by Chuck Sharman

On November 10, 2025, a jury in the U.S. District Court for the Eastern District of New York returned a $112 million verdict in favor of Plaintiffs in a class-­action suit accusing the Sheriff of Suffolk County of illegally detaining them in the County jail after their cases were resolved, solely for handover to federal Immigration and Customs Enforcement (ICE).

The district court had earlier agreed with the Plaintiff Class that the County violated their civil rights when their cases were concluded and they remained incarcerated pursuant to an ICE detainer. In the trial for damages that followed, a total of 674 Class members were awarded $112 million—$75 million for violation of their Fourth Amendment guarantee against unwarranted search and seizure, plus $37 million for violation of their Due Process rights.

Lead Plaintiff Joaquin Orellana Castañeda brought the suit in July 2017, accusing then-­Sheriff Thomas Spota of violating his civil rights following an arrest the previous April. After his arrest in Central Islip, County Police questioned Orellana Castañeda’s immigration status before he was booked into the County’s Yaphank Correctional Facility on a $1,000 bail. While there, he was also interviewed on April 24 by ICE agents, who assured him that he would be released upon payment of the bail to await a future immigration hearing. Orellana Castañeda’s cousin paid his bail that same day. Yet he was not released; ICE issued a detainer that same day to the Sheriff’s Office (SCSO), which continued to hold him.

The detainer does not represent a criminal charge; an immigration violation is a civil matter. All that a detainer can do is request that the incarcerating agency hold the suspect up to 48 hours after his scheduled release. Crucially, it instructs that the detainee must sign for a copy of the detainer and warrant. But no one ever told Orellana Castañeda that the detainer existed, much less got him to sign an acknowledgement for it. The portion of the warrant attached to the April 24 detainer that should have been filled out with details regarding its service was left blank.

On April 26, someone at the jail told Orellana Castañeda that there had been a change in his paperwork, but no more details were offered. On April 27, he was transferred to another County lockup, the Riverhead Correctional Facility. ICE picked him up there and took him to its New York City office, where he was shown a different copy of the detainer and warrant, this one dated April 26 and signed by an ICE officer, not Orellana Castañeda. From there, he was taken to New Jersey’s Bergen County Jail and held in a cell rented by ICE. He was still there three months later when his complaint was filed in the district court.

A Troubled History
on Shaky Legal Ground

Just months before, in February 2017, the New York State Sheriff’s Association had advised its members, including SCSO, not to honor detainers past a prisoner’s scheduled release date unless there was a judicial warrant attached. That was because numerous local law enforcement agencies who honored detainers without a judicial warrant had been found liable for a Fourth Amendment violation, as PLN reported. [See: PLN, Nov. 2016, p.8.] SCSO ignored the warning, leading to Orellana Castañeda’s suit.

On August 31, 2022, a magistrate at the district court recommended granting certification to a class consisting of “[a]ll persons who, from [July 18], 2014 through November 15, 2018, were detained by the [SCSO] and against whom [ICE] issued an immigration detainer request pursuant to which SCSO continued to detain the individual after SCSO’s detention authority had expired.” The district court subsequently adopted the recommendation on July 1, 2024. See: Castaneda v. Cty. of Suffolk, 2022 U.S. Dist. LEXIS 157842 (E.D.N.Y.); and2024 U.S. Dist. LEXIS 119874 (E.D.N.Y.).

The parties filed cross-­motions for summary judgment, and the district court ruled on January 2, 2025, that Plaintiffs had sustained their claim for a Fourth Amendment violation. As the court noted, ICE can make its detainer requests to local law enforcement, but the latter has no probable cause to arrest and hold someone not otherwise in custody, unless it has entered into a written agreement with ICE pursuant to 8 C.F.R. § 287.

Even then, the district court continued, there is significant disagreement among courts whether § 287 confers probable cause. But there is certainly none without it, and SCSO had no signed agreement with ICE. Instead it relied on a “longstanding” agreement with the U.S. Marshals Service to house federal detainees at the County’s Riverhead lockup. Quoting a state appellate court ruling—in another challenge to an SCSO detention for ICE—the district court said that “the Sheriff’s policy, issued on December 2, 2016, directing the retention of prisoners, who would otherwise be released, pursuant to ICE detainers and administrative warrants is unlawful.” See: People ex rel. Wells v. DeMarco, 168 A.D.3d 31 (N.Y. App. Div. 2d Dep’t 2018).

While Wells did not address whether a Fourth Amendment violation resulted, the district court went on to decide that Orellana Castañeda and his fellow class members had suffered exactly that, and Suffolk County was liable. Defendants were granted summary judgment on Plaintiffs’ Fourteenth Amendment due process claims, but only because the district court found them duplicative of the due process claims inherent in the Fourth Amendment claims. See: Castaneda v. Cty. of Suffolk, 2025 U.S. Dist. LEXIS 26726 (E.D.N.Y.).

Defendants Try Once More

Defendants then took a swing at reviving a portion of their rejected defense—that they were entitled to summary judgment based on federal immunity, since they were holding Plaintiffs for ICE, which is a federal agency. In essence, they argued that they acted as if they had a valid § 287 agreement, so that’s how they should be treated. The district court denied that motion, too, on September 29, 2025.

The immunity defense was waived, the district court said, when Defendants waited eight years to raise it in their summary judgment motion that was denied. Defendants objected that they should be entitled to the same deference as federal actors when claiming federal immunity. But the district court said simply: “They are wrong.”

“As state actors, Defendants are not entitled to an unwaivable presumption of federal sovereign immunity,” the district court declared. See: Castaneda v. Cty. of Suffolk, 2025 U.S. Dist. LEXIS 222979 (E.D.N.Y.).

That set up the case for the jury, which was seated for the damages trial on November 4, 2025. When they concluded, jurors returned the enormous verdict, reflecting their assessment of just how severely Plaintiffs were injured by SCSO’s cavalier disregard of their constitutional rights—in fact, Orellana Castañeda’s testimony had to be offered remotely from Guatemala, where ICE has deported him.

Plaintiffs have moved for an additional award to cover their legal costs and fees in this long-­running suit, and PLN will update those details when judgment issues. The class is represented by counsel from New York City attorneys Jose L. Perez, Juan Cartagena and Stephanie M. Cordero with LatinoJustice Pride, as well as Jara R. Y. Jacobson, Michelle D. Tuma and Aldo A. Badini with Winston & Strawn LLP. See: Castaneda v. Cty. of Suffolk, USDC (E.D.N.Y.), Case No. 2:17-­cv-­04267.  

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