Shorter v. Baca, No. 16-56051 (9th Cir. 2018)
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If plaintiffs in 42 U.S.C.1983 actions demonstrate that their conditions of confinement have been restricted solely because of overcrowding or understaffing at a prison facility, a deference instruction ordinarily should not be given. Similarly, if plaintiffs in 42 U.S.C. 1983 actions demonstrate that they have been subjected to search procedures that are an unnecessary, unjustified, or exaggerated response to concerns about jail safety, the court need not defer to jail officials.
Plaintiff appealed the partial grant of summary judgment for defendants on her 42 U.S.C. 1983 action alleging inadequate medical care, and the denial of her motion for a new trial. Plaintiff challenged several conditions of her confinement and the procedures that the County used to classify her as mentally ill. The Ninth Circuit held that the magistrate judge should not have given the deference instruction to plaintiff's conditions of confinement claims, where the only justification that jail officials offered for curtailing her meals, showers, and recreation was a concern about overcrowding and understaffing in the facility. The panel also held that the magistrate judge erred in instructing the jury to give deference to the jail officials on plaintiff's claim of excessive search, because substantial evidence supporter her arguments that this search practice was an unnecessary, unjustified, and exaggerated response to jail officials’ need for prison security. Accordingly, the panel vacated and remanded.
Court Description: Prisoner Civil Rights The panel vacated a partial grant of summary judgment, reversed the denial of a new trial, and remanded for further proceedings in a 42 U.S.C. § 1983 action brought by a pretrial detainee who alleged inadequate medical care, unconstitutional conditions of confinement, and humiliating and invasive strip searches. The panel first noted that plaintiff presented uncontroverted evidence at trial that the County of Los Angeles, tasked with supervising high-observation housing for mentally ill women, has a policy of shackling the women to steel tables in the middle of an indoor recreation room as their sole form of recreation, and that jail officials routinely left noncompliant detainees naked and chained to their cell doors, for hours at a time without access to food, water, or a toilet.
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