Castro v. County of Los Angeles, No. 12-56829 (9th Cir. 2015)
Annotate this CaseDefendant filed suit against the County, the Sheriff's Department, and individual defendants after he was savagely attacked by an intoxicated arrestee who had been placed in a "sobering cell" with plaintiff. The jury returned a verdict for plaintiff against both the individual and entity defendants for past and future damages. On appeal, defendants challenged the denial of their motion for judgment as a matter of law. The court concluded that neither the individual defendants, plaintiff's jailers, is entitled to qualified immunity where the duty to protect plaintiff from violence was clearly established at the time of the incident; the jury could have found that Defendant Solomon was deliberately indifferent to a substantial risk of harm to plaintiff because he disregarded plaintiff's pounding on the cell door; and the jury could have found that Defendant Valentine was deliberately indifferent to a substantial risk of harm to plaintiff when he placed the attacker in plaintiff's cell. In regards to punitive damages, no additional evidence is required to make a finding of "reckless disregard" when a finding of "deliberate indifference" has been made. Accordingly, the court affirmed the judgment against the individual defendants. However, the court reversed the judgment against the County where plaintiff's claims under Monell v. Dep't of Soc. Servs. was legally viable but there was no evidence that the County had actual knowledge of the risk of plaintiff's safety. Further, plaintiff presented sufficient evidence regarding the amount of past damages.
Court Description: Civil Rights. The panel affirmed in part and reversed in part the district court’s judgment, entered following a jury trial, in an action brought under federal and state law by a pretrial detainee who was attacked by another arrestee and suffered serious harm. Affirming the judgment in favor of plaintiff against the individual defendants, the panel held that defendants were not entitled to qualified immunity because the right to be free from violence at the hands of other inmates was well established and there was sufficient evidence for a jury to find that the officials were deliberately indifferent to a substantial risk of harm to plaintiff. The panel further found that there was sufficient evidence for the punitive damages award. Reversing the judgment in favor of plaintiff against the County of Los Angeles and the Los Angeles Sheriff’s Department, the panel held that plaintiff’s claim under Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 690–71 (1978), was legally viable but insufficiently proven. The panel held that although the entity defendants instituted a formal policy under Monell with regard to designing the jail’s sobering cell, there was insufficient evidence that they had actual knowledge of the risk to plaintiff’s safety. The panel affirmed the jury’s future-damages award, determining that plaintiff presented sufficient evidence CASTRO V. COUNTY OF LOS ANGELES 3 regarding the amount of his past damages from which a jury could reasonably calculate the amount of future damages. Concurring, Judge Callahan agreed that the judgment of the district court against the individual defendants should be affirmed and the judgment against the entity defendants should be reversed. She wrote separately to explain that she did not think that plaintiff had shown that the design of the West Hollywood Station constituted a policy for purposes of liability under Monell. Concurring in part and dissenting in part, Judge Graber joined the majority opinion as to the liability of the individual defendants. She dissented from the holding that there was insufficient evidence from which the jury could have concluded that the entity defendants were deliberately indifferent to the risk that plaintiff would be harmed by a fellow inmate.
The court issued a subsequent related opinion or order on August 11, 2015.
The court issued a subsequent related opinion or order on December 28, 2015.
The court issued a subsequent related opinion or order on August 15, 2016.
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