King v. County of Los Angeles, No. 14-55320 (9th Cir. 2018)
Annotate this CasePlaintiff 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.
Court Description: Civil Rights. The panel reversed the district court’s grant of summary judgment in favor of the County of Los Angeles and Sheriff Baca in his official capacity, and affirmed the district court’s grant of summary judgment in favor of Sheriff Baca in his individual capacity in an action brought pursuant to 42 U.S.C. § 1983 by a civil detainee alleging that the conditions of his confinement violated substantive due process. Plaintiff was incarcerated in a Los Angeles County jail for almost eight years as a civil detainee while awaiting the adjudication of an involuntary commitment petition under California’s Sexually Violent Predator Act. For more than six of his years in the County jail, plaintiff was confined in Administrative Segregation along with criminal detainees. Citing Jones v. Blanas, 393 F.3d 918, 931–35 (9th Cir. 2004), the panel first noted that under the Due Process Clause of the Fourteenth Amendment, an individual detained under civil process cannot be subjected to conditions that amount to punishment. Under Jones, conditions are presumptively punitive if (1) they are similar to those that a pre-trial detainee’s criminal counterpart would face, and (2) are more restrictive than conditions faced by individuals following civil commitment. The panel then held that plaintiff’s confinement triggered both of the presumptions set forth in Jones. As to the first presumption, the panel concluded that KING V. COUNTY OF LOS ANGELES 3 sexually violent predator detainees in the Twin Towers Correctional Facility were subject to essentially the same conditions of confinement as their criminal counterparts. As to the second presumption, the panel concluded that conditions in the sexually violent predator unit in the facility were more restrictive than conditions at Coalinga State Hospital. The panel further held that plaintiff’s confinement in administrative segregation also triggered both Jones’ presumptions. The panel held that on remand, the district court, in evaluating any rebuttal to the Jones presumptions, should consider the conditions in the Los Angeles County jails to determine whether, given those conditions and the realities facing the jail administrators, it is possible to rebut the Jones presumptions for sexually violent predator detainees held in those jails. In affirming the district court’s summary judgment in favor of Sheriff Baca in his individual capacity, the panel held that the record did not establish that Sheriff Baca supervised the day-to-day operations of the correctional facility, that he was personally involved in any constitutional deprivation plaintiff may have suffered, or the requisite causal connection for liability in his individual capacity. The panel did not reach the question whether the district court was correct in its application of Younger v. Harris, 401 U.S. 37 (1971), for plaintiff’s claim for injunctive relief has been mooted by his transfer to Coalinga State Hospital and by his death in the fall of 2017. In light of plaintiff’s death during the pendency of this appeal, the panel instructed the clerk of this court to hold the mandate for ninety days, pending a motion for substitution of a personal representative 4 KING V. COUNTY OF LOS ANGELES under Federal Rule of Appellate Procedure 43(a)(1). If no motion for substitution was filed within ninety days, the panel held that this appeal would be subject to dismissal as moot.
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