King v. County of Los Angeles, No. 14-55320 (9th Cir. 2018)Annotate this Case
Plaintiff filed suit under 42 U.S.C. 1983, alleging that the conditions of his confinement as a civil detainee while awaiting the adjudication of an involuntary petition under California's Sexually Violent Predator Act violated substantive due process. The Ninth Circuit held that plaintiff's confinement triggered both presumptions under Jones v. Blanas, 393 F.3d 918, 931–35 (9th Cir. 2004), that the conditions of his civil detention amounted to punishment. In this case, sexually violent predator detainees in the Twin Towers Correctional Facility were subject to essentially the same conditions of confinement as their criminal counterparts, and conditions in the sexually violent predator unit in the facility were more restrictive than conditions at Coalinga State Hospital. The panel reversed the district court's grant of summary judgment on plaintiff's claims for damages against the County and against the sheriff in his official capacity; affirmed the district court's grant of summary judgment as to plaintiff's claims for damages against the sheriff in his individual capacity; and noted that plaintiff's claim for injunctive relief was moot because he died during the pendency of this appeal.