Sandoval v. County of San Diego, No. 18-55289 (9th Cir. 2021)
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Sandoval died of a methamphetamine overdose at the San Diego Central Jail after medical staff left him unmonitored for eight hours, despite signs that he was under the influence of drugs, and then failed to promptly summon paramedics when they discovered him unresponsive and having a seizure. A suit under 42 U.S.C. 1983 was rejected on summary judgment.
The Ninth Circuit reversed. The district court abused its discretion by summarily sustaining the defendants’ “frivolous” evidentiary objections. An objective standard applies to constitutional claims of inadequate medical care brought by pretrial detainees; the district court erroneously applied the subjective deliberate indifference standard. A jury could conclude that Sandoval would not have died but for the defendants’ unreasonable response to his obvious signs of medical distress and that a reasonable nurse who was told that Sandoval was shaking, tired, and disoriented, and who was specifically directed by a deputy to evaluate Sandoval more thoroughly, would have understood that Sandoval faced a substantial risk of serious harm. Failure to check on Sandoval and to promptly call paramedics were objectively unreasonable. The available law was clearly established at the time. The nurses were not entitled to qualified immunity. Viewing the evidence in the light most favorable to the plaintiff, there was a triable issue of fact as to the county’s liability.
Court Description: Civil Rights The panel ordered the appeal resubmitted, reversed the district court’s summary judgment and remanded in an action brought pursuant to 42 U.S.C. § 1983 against the County of San Diego and three nurses alleging that defendants violated Ronnie Sandoval’s Fourteenth Amendment right to adequate medical care while he was in custody at the San Diego Central Jail. Sandoval died of a methamphetamine overdose at the San Diego Central Jail after medical staff left him unmonitored for eight hours, despite signs that he was under the influence of drugs, and then failed to promptly summon paramedics when they discovered him unresponsive and having a seizure. Concluding that the district court abused its discretion by summarily sustaining the defendants’ meritless—indeed * The Honorable Joseph F. Bataillon, United States District Judge for the District of Nebraska, sitting by designation. SANDOVAL V. COUNTY OF SAN DIEGO 3 frivolous—evidentiary objections, the panel considered the objected-to evidence. Turning to the merits, the panel first noted that after the district court issued its decision, this court clarified in Gordon v. County of Orange, 888 F.3d 1118, 1124–25 (9th Cir. 2018), that an objective standard applies to constitutional claims of inadequate medical care brought by pretrial detainees. In light of Gordon, the district court erred by applying the subjective deliberate indifference standard to plaintiff’s Fourteenth Amendment claim. Because the parties had briefed Gordon’s objective framework on appeal, the panel applied it here. Applying the Gordon framework and viewing the evidence in plaintiff’s favor, the panel held that a jury could conclude that Sandoval would not have died but for the defendants’ unreasonable response to his obvious signs of medical distress. Specifically, a jury could conclude that a reasonable nurse who was told that Sandoval was shaking, tired, and disoriented—and who was specifically directed by a deputy to evaluate Sandoval more thoroughly—would have understood that Sandoval faced a substantial risk of suffering serious harm. Defendant Nurse Romeo de Guzman therefore was not entitled to summary judgment on liability. The panel reached the same conclusion for the claims against Nurses Dana Harris and Maria Llamado, concluding that their failure to promptly call paramedics was objectively unreasonable. The panel further held that plaintiff had demonstrated that the available law was clearly established at the time as to the unreasonableness of the nurses’ conduct. The panel concluded that a reasonable nurse, knowing what Llamado, Harris, and de Guzman knew, would have understood that failing to call paramedics (Llamdo and Harris), or failing to check on Sandoval for hours and failing to pass on 4 SANDOVAL V. COUNTY OF SAN DIEGO information about his condition (de Guzman), presented such a substantial risk of harm to Sandoval that the failure to act was unconstitutional. Accordingly, the nurses were not entitled to qualified immunity. The panel held that viewing the evidence in the light most favorable to plaintiff, there was a triable issue of fact as to the County’s liability under Monell v. Department of Social Services, 436 U.S. 658, 694 (1978). Concurring in the judgment in part and dissenting in part, Judge Collins agreed with the majority’s ultimate conclusion that Nurses Harris and Llamado were not entitled to summary judgment, but he would affirm the district court’s grant of summary judgment to Nurse de Guzman and to the County of San Diego. Judge Collins wrote that because in 2014, the then controlling deliberate-indifference liability standards included a subjective element, plaintiff had to make a showing of subjective deliberate indifference to defeat qualified immunity, and she had to do so even though that subjective element of the test for liability has since been overruled. Because plaintiff failed to present sufficient evidence to show that Nurse de Guzman was subjectively aware of Sandoval’s serious medical needs, de Guzman was entitled to qualified immunity. Judge Collins further stated that there was no evidence that the County had an unconstitutional policy, practice or custom. Finally, as to Nurses Harris and Llamdo, the sharply conflicting evidence indicated that they subjectively knew that the paramedics needed to be called. Because Judge Collins’s reasoning differed from the majority’s even with respect to Harris and Llamado, he concurred only in the judgment in part, and otherwise respectfully dissented. SANDOVAL V. COUNTY OF SAN DIEGO 5
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