Serafin Rangel-Sambrano v. Adams County Sheriff’s Office, Adams County, Evan Armstrong, Corporal, Adams County Sheriff’s Office, in his individual capacity; Dale Wagner, Sheriff, Adams County Sheriff’s Office, in his individual and official capacity

District Court, E.D. Washington·Decided January 20, 2026·No. 2:25-cv-00003·Unknown

Opinion

U.S. F D IL IS E T D R I I N C T T H C E O URT EASTERN DISTRICT OF WASHINGTON Jan 20, 2026 SEAN F. MCAVOY, CLERK No. 2:25-CV-00003-RLP Plaintiff, v. ORDER ON MOTION ADAMS COUNTY SHERIFF’S OFFICE, ARMSTRONG, Corporal, Adams County Sheriff’s Office, in his individual capacity; DALE WAGNER, Sheriff, Adams County Sheriff’s Office, in his individual and official capacity, Defendants.

BEFORE THE COURT is Defendants’ Motion for Summary Judgment, ECF No. 13. Plaintiff is represented by Aaron Korthuis, Glenda Melinda Aldana Madrid, Leila Kang, Matthew H. Adams, and Amanda Ng. Defendants are represented by Jeremy W. Culumber and Anthony Scott Marinella. This matter was submitted for consideration without oral argument. Plaintiff Serafin Rangel-Sambrano’s Complaint centers on the allegation that Defendants unlawfully detained him after he was released from local criminal charges. Defendants deny any wrongdoing. They contend there was no prolonged

detention; Mr. Rangel-Sambrano was released pursuant to standard protocol. Alternatively, Defendants argue that, even if there was a prolonged detention, this was not illegal. Based on a legal rule known as the collective knowledge doctrine,

Defendants argue Adams County Sheriff’s deputies had probable cause to arrest Mr. Rangel-Sambrano for a criminal violation of U.S. Immigration law. Thus, to the extent Mr. Rangel-Sembrano was detained beyond what was necessary to process his local charges, this detention was lawful.

Having reviewed the record and parties’ arguments, the Court concludes issues of fact largely preclude granting Defendants’ motion. While the Adams County Sheriff’s Office is entitled to relief, given that it does not legally qualify as

an entity amenable to suit, Mr. Rangel-Sambrano’s claims against the remaining defendants survive summary judgment. In the evening hours of March 9, 2023, Adams County Sheriff’s deputies

arrested Mr. Rangel-Sembrano and a companion on suspicion of possessing a stolen vehicle. ECF No. 14-1 (Exh. 1). During post-arrest interviews, Mr. Rangel- Sembrano and his companion made statements suggesting possible involvement with a well-known drug trafficker. ECF No. 16 ¶¶ 4-6. To follow up, Sherriff’s Sergeant Juan Garcia contacted the Department of Homeland Security (DHS) about whether Mr. Rangel-Sembrano or his companion may have been the subjects

of a narcotics investigation. Id. Sergeant Garcia spoke with Border Patrol Agent Cody Mumau. Id. at ¶¶8-9. Agent Mumau told Sergeant Garcia he was unaware of any pending investigation

involving Mr. Rangel-Sambrano or his companion. Id. Agent Mumau also conducted a telephone interview of Mr. Rangel- Sembrano. ECF No. 18, ¶4. During the interview, Mr. Rangel-Sembrano admitted that he was a Mexican citizen, that he had been in the United States for a

significant amount of time, that he had never been lawfully admitted into the United States, and that he had no documentation allowing him to be in the country. Id. There is no indication Agent Mumau shared the foregoing information from

Mr. Rangel-Sembrano with anyone at Adams County. Additionally, no one from Adams County asked Mr. Rangel-Sembrano about his immigration status. Mr. Rangel-Sembrano and his companion were initially processed by Adams County correctional staff. ECF No. 14-12 (Exh. 9). However, because the Adams

County Jail was closed to overnight housing, sheriff’s deputies transported Mr. Rangel-Sembrano and his companion to Franklin County Jail where the county had an agreement for overnight jail services. ECF No. 28-4. That evening, Agent Mumau issued an immigration detainer for Mr. Rangel- Sembrano to the Franklin County Jail. ECF No. 18, ¶5. Adams County was not provided the detainer. ECF No. 19, ¶6.

The next morning, the Adams County Prosecutor declined to file charges. ECF No. 14-15 (Exh. 12). Later that afternoon, the district court notified the sheriff’s office that Mr. Rangel-Sembrano was released on his own recognizance.

ECF No. 14-16 (Exh. 13) at 2. The sheriff’s office then emailed the Franklin County Jail that a deputy would be picking up Mr. Rangel-Sembrano and his companion for transport back to Adams County for release. ECF No. 14-17 (Exh. 14).

A remark in the Franklin County booking report lists Mr. Rangel-Sembrano as “Released by Court.” ECF No. 14-14 (Exh. 11) at 3. The report states Mr. Rangel-Sembrano was released via a “Transfer to Other Jail.” Id. Below this

statement is the following comment: “3/10/23 rels to adams co transporting to [Ritzville] for [Spokane] border patrol F534.” Id. Adams County’s transport notes indicate a sheriff’s deputy arrived at the Franklin County Jail at 2:56 p.m. on March 10. ECF No. 14-13 (Exh. 10) at 2. The notes further specify the officer was

en route as of 3:29 p.m. with the description, “RITZVILLE W/2 FOR BORDER PATR.” Id. Mr. Rangel-Sembrano arrived back at the Adams County jail at 4:26 p.m. Id. In his deposition, Mr. Rangel-Sembrano alleges he remained at the jail, in handcuffs, for approximately 10-15 minutes before being taken into custody by a different law enforcement officer. ECF No. 14-19 (Exh. 16) at 9. According to

DHS records, a border patrol agent contacted Mr. Rangel-Sambrano at the Ritzville County Jail at approximately 5:00 p.m. on March 10, 2023. ECF No. 14-11 (Exh. 8) at 4. Mr. Rangel-Sembrano was then taken into immigration custody and

processed for administrative removal proceedings. Id. Mr. Rangel-Sembrino filed suit in the Eastern District of Washington against Defendants Adams County Sheriff’s Office, Adams County, Evan Armstrong and Dale Wagner. He alleges claims under Section 1983 for unlawful detention against

Adams County Sheriff’s Office, Adams County and Evan Armstrong, and for failure to train and/or supervise against Adams County Sheriff’s Office, Adams County and Dale Wagner; false arrest against Adams County Sheriff’s Office,

Adams County and Evan Armstrong; and discrimination under the Washington Law Against Discrimination (WLAD) against all defendants. Defendants filed a motion for summary judgment, seeking relief on all claims.

Summary judgment will be granted if the moving party “shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FRCP 56(a). In ruling on a motion for summary judgment, the Court views the evidence and inferences therefrom “in the light most favorable to the adverse party.” James River Ins. Co. v. Herbert Schenk, P.C., 523 F.3d 915, 920 (9th Cir. 2008) (quoting Jones v. Halekulani Hotel, Inc., 557 F.2d 1308, 1310

(9th Cir. 1977)). “A fact issue is genuine ‘if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.’” Villiarimo v. Aloha Island Air, Inc., 281 F.3d 1054, 1061 (9th Cir. 2002) (quoting Anderson v. Liberty Lobby,

Inc., 477 U.S. 242, 248, 106 S.Ct. 2505 (1986)). Mr. Rangel-Sembrano’s legal claims are premised on the argument that he was illegally detained by Adams County Sheriff’s deputies after being ordered released from local charges on March 10, 2023. According to Defendants, Mr.

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Serafin Rangel-Sambrano v. Adams County Sheriff’s Office, Adams County, Evan Armstrong, Corporal, Adams County Sheriff’s Office, in his individual capacity; Dale Wagner, Sheriff, Adams County Sheriff’s Office, in his individual and official capacity, (E.D. Wash. 2026).

Serafin Rangel-Sambrano v. Adams County Sheriff’s Office, Adams County, Evan Armstrong, Corporal, Adams County Sheriff’s Office, in his individual capacity; Dale Wagner, Sheriff, Adams County Sheriff’s Office, in his individual and official capacity (Serafin Rangel-Sambrano v. Adams County Sheriff’s Office, Adams County, Evan Armstrong, Corporal, Adams County Sheriff’s Office, in his individual capacity; Dale Wagner, Sheriff, Adams County Sheriff’s Office, in his individual and official capacity) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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