Mendiola-Martinez v. Arpaio, No. 14-15189 (9th Cir. 2016)
Annotate this CasePlaintiff was in the custody of Maricopa County for a nonviolent offense when she gave birth to her son. After her release, she filed suit under 42 U.S.C. 1981 & 1983, alleging that her constitutional rights were violated when, among other things, she was shackled and restrained during labor and postpartum recovery. The district court granted summary judgment for the County Defendants and the Medical Center on all of plaintiff's claims, and taxed costs against her. The court addressed an issue of first impression: whether the U.S. Constitution allows law enforcement officers to restrain a female inmate while she is pregnant, in labor, or during postpartum recovery. The court held that, in this case, the answer to that question depends on factual disputes a properly instructed jury must resolve. Therefore, the court vacated and remanded the district court’s grant of summary judgment for the County Defendants on most of plaintiff's shackling claims. The court affirmed the grant of summary judgment in favor of the County Defendants on the remaining claims, and affirmed summary judgment on all claims against the Medical Center. The court vacated the cost award to the County Defendants and remanded, but the court affirmed the cost award to the Medical Center.
Court Description: Prisoner Civil Rights. The panel affirmed in part and vacated in part the district court’s summary judgment and award of costs in favor of defendants and remanded in an action brought under 42 U.S.C. §§ 1981 & 1983, by a former female prisoner who alleged that her constitutional rights were violated when, among other things, she was shackled and restrained during her labor and postpartum recovery. The panel vacated summary judgment for the County Defendants on the shackling claims as they related to shackling while plaintiff was in labor and leaving the Maricopa County Medical Center after the birth of her son, as well as the separately pleaded claim under Monell v. New York City Department of Social Services, 436 U.S. 658 (1978), insofar as it concerns these alleged shackling MENDIOLA-MARTINEZ V. ARPAIO 3 incidents. The panel held that plaintiff presented sufficient evidence for a reasonable jury to conclude that by restraining her when she was in labor and postpartum recovery, the County Defendants exposed her to a substantial risk of serious harm. The panel further determined that a jury could conclude that the County Defendants were aware of the risk caused by restraining an inmate in labor and deliberately indifferent to that risk by restraining her during transport to the Medical Center where she had her baby. The panel remanded for a jury to determine whether the risk posed to plaintiff by the County’s restraint policy was justified, or whether the County Defendants went too far. The panel affirmed the district court’s summary judgment for the County Defendants on plaintiff’s remaining claims regarding a postpartum leg tether, medical supplies, pregnancy diet and nutrition, and equal protection. Because the County Defendants were no longer the prevailing party on all of their claims, the panel vacated the cost award in favor of the County Defendants and remanded to the district court to determine those costs. The panel affirmed summary judgment in favor of the Medical Center on all of plaintiffs’ claims and likewise affirmed the cost award in its favor. 4 MENDIOLA-MARTINEZ V. ARPAIO
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