Sacramento County could face sanctions in wrongful imprisonment discovery dispute

SACRAMENTO, Calif. (CN) — A man who wrongly spent almost two decades in prison urged a federal judge Friday to hold three California government agencies in contempt for failing to produce documents in a civil case against them.

U.S. District Chief Judge Kimberly Mueller, a Barack Obama appointee, took the matter into submission but made no immediate decision.

Wrongly imprisoned on murder and robbery charges, Puckett in 2022 sued Sacramento County along with its sheriff’s department and district attorney’s office. He argues Sacramento County’s “reckless and intentional misconduct” led to his incarceration. He’s sought personnel and disciplinary records from the three entities.

The disclosure of those records, as well as the agencies’ failure to produce all of them, led U.S. Magistrate Judge Deborah Barnes in June to set Friday’s hearing. From there, the agencies needed to show why Mueller shouldn’t hold them in contempt.

For around two years, Puckett has struggled to get documents from the agencies, his attorney Anna Veross told the court Friday.

Deadlines to hand over documents have been pushed back twice, she said. In addition, Barnes had issued seven orders compelling the agencies to provide the documents.

“We believe that there’s significant prejudice here,” Veross said.

Previously, Barnes had ordered the agencies to detail specific information about the searches they performed for documents.

Based on the records received, Veross said Sacramento County had not apparently turned over all relevant documents. Multiple yearly performance evaluations were missing, Veross said.

Barnes shared those concerns. In the order setting Friday’s hearing, she called the agencies’ responses “vague” and “devoid of sufficient information.”

Representing the county, attorney John Whitefleet has disputed that characterization. On Friday, he told Mueller there’s no evidence of missing documents and that specific searches were conducted that would have revealed any pertinent information.

“They have everything that the sheriff’s office has, that the county has, that the district attorney has,” Whitefleet said.

Concerning any missing disciplinary records, Whitefleet reiterated there’s no evidence such documents exist.

Unrelated disciplinary documents revealed by a search were handed over, he said. Additionally, he said Puckett has refused to set dates for depositions on the grounds that the agencies haven’t provided all the requested documents — even though he said it’s only speculation that more documents exist.

Skeptical, Mueller referenced one response agencies gave to a request for certain documents.

In that case, the agencies also stated records didn’t exist. But after complying with a court order to search for the documents, the agencies found them.

“Not just a few pages, or a few hundred pages, but over 4,000 pages,” Barnes previously wrote. Whitefleet, however, contended there had simply a misreading of Puckett’s request.

Puckett has asked the federal court to reach certain findings of fact. Among them, he wants the court to say that Sacramento County agencies created a reckless culture that caused injury, that the county and district attorney’s office failed to conduct proper monitoring of employees and that detectives withheld evidence from a witness.

Veross said the judge could consider the range of bad acts when deciding on sanctions. Whitefleet argued the case wasn’t about whether detectives showed a picture to someone. As for the judge herself, she appeared to fall somewhere in the middle.

“I’m not inclined to bless everything,” Mueller said of Puckett’s request.

Pivoting to another issue in the case, the judge asked about Whitefleet’s failure to meet and speak with Puckett’s attorneys before filing a motion for reconsideration. That motion concerned a May ruling from Barnes sanctioning the agencies $27,100 — an amount based off attorney fees.

Mueller said attorneys for both sides should have conferred before Whitefleet filed the motion. Last week, she also said Whitefleet needed to explain why she shouldn’t sanction him $750 over the issue.

Whitefleet said Barnes’ order for sanctions doesn’t directly state that a meeting between attorneys is needed. With that, Mueller ended the hearing. “At this point," she said, “think I have what I need.”