Does post-arrest incarceration apply to the Fourteenth Amendment?

MultiRegion, United States of America

The following excerpt is from Leon v. City of Merced, Corp., No. 1:14-CV-01129-GEB-SAB (E.D. Cal. 2015):

However, "[p]recedent demonstrates . . . that post-arrest incarceration is analyzed under the Fourteenth Amendment alone." Rivera v. County of Los Angeles, 745 F.3d 384, 389-90(9th Cir.2014).

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