D.Haw.: No constitutional right to an “adequate police investigation”

There is no constitutional right to an “adequate police investigation.” Hawkes v. Katayama, 2026 U.S. Dist. LEXIS 59452 (D. Haw. Mar. 19, 2026):

“[A]n inadequate investigation by police officers is not sufficient to state a § 1983 claim unless another recognized constitutional right is involved, such as failure to protect against discrimination.” Sexual Sin de un Abdul Blue v. City of Los Angeles, No. CV 09-7573, 2010 WL 890172, at *6 (C.D. Cal. Mar. 8, 2010); see also Gomez v. Whitney, 757 F.2d 1005, 1006 (9th Cir. 1985) (“[W]e can find no instance where the courts have recognized inadequate investigation as sufficient to state a civil rights claim unless there was another recognized constitutional right involved.”).