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
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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