Rodriguez v. County of Los Angeles, No. 13-56292 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed the district court's judgment for plaintiffs in a 42 U.S.C. 1983 action brought by five prisoners who were severely injured during cell extractions in two high security units. The panel held that the district court lacked jurisdiction to proceed to trial during the pendency of an interlocutory appeal from a prior qualified immunity ruling, but the error was harmless; in regard to the exhaustion of administrative remedies under the Prison Litigation Reform Act, the district court did not clearly err in finding that a reasonable fear of retaliation made the grievance system effectively unavailable for plaintiffs because they reasonably believed that they would suffer additional physical force if they complained; the district court did not err by denying defendants' Rule 50(b) motion based on qualified immunity where there was abundant evidence presented to the jury that defendants inflicted severe injuries on plaintiffs while they were not resisting, and even while they were unconscious; and the panel rejected claims under state law as well as claims of Monell liability, juror bias, punitive damages, and trial errors. Finally, the panel affirmed the district court's attorney's fee award of $5,378,174.66.
Court Description: Prisoner Civil Rights. The panel affirmed the district court’s judgment in favor of plaintiffs following a jury trial, award of compensatory and punitive damages, and award of attorney’s fees in a 42 U.S.C. § 1983 action brought by five prisoners who were severely injured during the course of cell extractions at the Los Angeles County Men’s Central Jail. The panel first denied appellants’ request to vacate the final judgment on the basis that the district court lacked jurisdiction to go to trial during the pendency of appellants’ interlocutory appeal from a prior qualified immunity ruling. The panel held that although the district court failed to certify pursuant to Chuman v. Wright, 960 F.2d 104, 105 (9th Cir. 1992), that the interlocutory appeal was frivolous, any error was harmless. 4 RODRIGUEZ V. CRUZ Addressing the issue of exhaustion of administrative remedies under the Prison Litigation Reform Act, the panel held that the district court did not clearly err in finding that a reasonable fear of retaliation made the grievance system effectively unavailable for appellees, and that appellants failed to carry their burden of proof showing otherwise. The panel held that the district court did not err by denying appellants’ Fed. R. Civ. P. 50(b) motion, based on qualified immunity, for judgment as a matter of law. The panel held that there was abundant evidence presented to the jury that appellants inflicted severe injuries on appellees while they were not resisting, and even while they were unconscious. A jury could reasonably reject appellants’ argument that they acted reasonably and instead determine that the force was not part of a good-faith effort to maintain or restore discipline. The panel therefore rejected appellants’ sufficiency of the evidence challenge to the jury’s finding of a constitutional violation. The panel also found unpersuasive appellants’ arguments that the law regarding their conduct was not clearly established. Addressing the liability of the deputy appellants, the panel held that no reasonable deputy in appellants’ position would have believed that beating a prisoner to the point of serious injury, unconsciousness, or hospitalization solely to cause him pain was constitutionally permissible. The panel rejected the argument that the limits on the proper use of tasers were still unclear as of 2008, stating that once a jury has determined on the basis of sufficient evidence that prison officials maliciously and sadistically used more than de minimis force to cause harm, contemporary standards of decency, and thus the Eighth Amendment, always are violated. RODRIGUEZ V. CRUZ 5 The panel held that the supervisor appellants—the sergeants who directed the extraction teams and their superiors—were not entitled to qualified immunity. The panel held that to the extent that these appellants stood by and observed the extractions but knowingly refused to terminate the deputies’ unconstitutional acts, they were individually liable. The panel determined that ample evidence—including appellants’ own testimony—supported the conclusion that appellants directed and observed most of the extraction teams. The panel held that although it was unclear whether Captain Cruz directly observed all of the extractions, a jury could reasonably find the requisite causal connection to hold Cruz liable for his own culpable action or inaction in the training, supervision, or control of his subordinates. The panel rejected the argument that the supervisors had immunity under state law and therefore could not be held liable under the Bane Act, California Civil Code § 52.1. The panel first held that California Civil Code § 820.2 does not shield government employees who use excessive force in carrying out their duties and that § 820.8 was inapplicable because appellees did not rely on vicarious liability. The panel concluded that in excessive force cases, including Eighth Amendment cases, § 52.1 does not require proof of coercion beyond that inherent in the underlying violation. Because appellees provided evidence sufficient to support a finding that they were subjected to excessive force in violation of the Eighth Amendment, they necessarily provided evidence sufficient to support a finding of a violation of their rights under the Bane Act. The panel held that the record amply supported the jury’s verdict and the district court’s ruling of municipal liability under Monell v. Dep’t of Soc. Servs. of City of New York, 6 RODRIGUEZ V. CRUZ 436 U.S. 658, 694 (1978). The panel held that there was substantial evidence of repeated constitutional violations, of the Los Angeles County Sheriff’s Department awareness of those violations, and of its failure to take any remedial action. The panel concluded that legal precedent permitted the jury to infer that the Sheriff’s Department had adopted a custom or practice of condoning excessive force and that this culture of violence and impunity proximately caused the injuries inflicted on appellees. The panel held that the record did not require a finding of implied juror bias that allegedly arose from the professional activities of a juror’s parents and the juror’s personal friendships with other individuals having some involvement with the prison system. The panel upheld the award of $210,000 in punitive damages award against the supervisory appellants, stating that the appellees proved egregious, even shocking, abuses of power. The panel further noted that the punitive damages awarded to each appellee, considered individually or together, were all far less than appellees’ compensatory damages. Addressing appellants’ claims of trial errors, the panel held that the district court acted within its broad discretion in declining to bifurcate the Monell claim and in excluding, under Federal Rule of Evidence 403, evidence of appellees’ felony convictions and their gang membership. The panel further found no error in the district court’s jury instructions and determined that the district court reasonably denied the application to compel live testimony for four appellees and non-party inmates. The panel affirmed the district court’s attorney’s fee award of $5,378,174.66. The panel held that the fee limit RODRIGUEZ V. CRUZ 7 provisions of the Prison Litigation Reform Act do not apply to attorney’s fees incurred in litigation under California Civil Code § 52.1. Finally, the panel found no fault in the district court’s decision to apply a 2.0 multiplier, given the financial risk assumed by appellees’ counsel, the difficulty of representing prisoners in an excessive force action against high-ranking jail officials who engage in aggressive opposition, and the opportunity costs that the years-long litigation in this case required. The panel noted that the district court had considered the burden to California’s taxpayers that the fee award would represent, and found that the award was justified given the factors described above and the importance of civil rights suits in protecting the public against abuses at the hands of large or politically powerful defendants. 8 RODRIGUEZ V. CRUZ
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