⚖ Oral Arguments, with Context

The United States Court of Appeals for the Ninth Circuit hears argument in Neaman versus Washington Department of Corrections. The case presents a false imprisonment claim arising from unusual facts. Chris Neaman was on community custody, a form of supervised release, when Washington Department of Corrections officers reported his violations to the prosecutor. Under Washington law, a court's authority to revoke community custody expires one year after the original sentencing date. Here, by the time the superior court held a hearing and ordered Neaman incarcerated, that one-year window had closed. Neaman appealed, and the Washington Court of Appeals reversed the superior court's order. The Department does not defend the extension, and told the Ninth Circuit that the state court had no authority to act once the one-year window closed. Whether that made the order merely erroneous or legally void is disputed in the argument you are about to hear. Neaman then sued the Department of Corrections in federal court, arguing that the officers who flagged his violations and filed reports to the prosecutor were responsible for his unlawful four hundred day confinement. The district court granted summary judgment to the state, finding no tort duty and no proximate cause. The core legal issue on appeal is whether Washington tort law imposes a duty on corrections officers to affirmatively correct or withdraw a violation report once the statutory deadline has passed, and whether their conduct was a legal cause of the imprisonment when a prosecutor, defense counsel, and judge all participated in the ultimately invalid court order.

Neaman v. Washington Department of Corrections (No. 25-3254) — U.S. Court of Appeals for the Ninth Circuit, argued August 4, 2026.