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Jan. 22, 2026

When 'no due process violation' becomes final: Payne v. Merced County and the vanishing federal remedy

A man lost 11 years to pretrial detention, but a single unappealed ruling blocked his federal due process claim--raising hard questions about justice, finality and systemic accountability.

K. Chike Odiwe

Civil Rights Attorney
The Law Offices of Kenneth C. Odiwe, PC

2880 Zanker Road, Ste 203
San Jose , CA 95134

Fax: (669) 315-4431

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When 'no due process violation' becomes final: <i>Payne v. Merced County</i> and the vanishing federal remedy
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Eleven years. That number should stop any lawyer who cares about due process in their tracks. In Payne v. Merced County Public Defender's Office, Jacob Payne spent more than 11 years detained while the state pursued a sexually violent predator determination, then he walked out only after a jury found the petition untrue.

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