Rivera v. Corrections Corporation of America, No. 20-15651 (9th Cir. 2021)
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The Ninth Circuit reversed the district court's grant of summary judgment for CoreCivic in an action brought by plaintiff under Nevada state law for torts related to his year-long detention in a private prison without a court hearing. The district court granted CoreCivic's summary judgment motion on the ground that CoreCivic did not cause plaintiff's prolonged detention.
The panel concluded that a jury could reasonably find that CoreCivic's actions caused plaintiff's prolonged detention. In this case, a rational jury could find that, in failing to notify the Marshals of plaintiff's detention and in dissuading and preventing him from seeking other help, CoreCivic was a cause of his pre-hearing detention as required to establish claims for false imprisonment, negligence, and intentional infliction of emotional distress. The panel also concluded that a jury could find that CoreCivic breached a duty to plaintiff, and thus plaintiff has established triable issues as to his negligence claim. Furthermore, a jury could reasonably find CoreCivic's actions extreme and outrageous, and thus plaintiff has established triable issues as to his claim for intentional infliction of emotional distress.
Court Description: Prisoner Civil Rights The panel reversed the district court’s summary judgment in favor of defendant CoreCivic, formerly Corrections Corporation of America, in an action brought under Nevada state law for torts related to plaintiff’s year- long detention in a private prison without a court hearing. The U.S. Marshals Service arrested plaintiff on a warrant for marijuana-related charges and housed him in a private prison run by CoreCivic. Instead of being brought promptly to court, plaintiff spent 355 days in solitary confinement without a court appearance. After his release, plaintiff sued CoreCivic and CoreCivic employees in federal court for false imprisonment, negligence, and intentional infliction of emotional distress under Nevada law. The district court entered judgment in CoreCivic’s favor, finding that CoreCivic did not cause plaintiff’s prolonged detention because it could not schedule a hearing for plaintiff or release him. The panel held that a reasonable jury could find that CoreCivic caused plaintiff’s prolonged detention by failing to notify the Marshals of his continued detention without a hearing and by discouraging and preventing him from seeking outside help. A jury could reasonably find that CoreCivic breached a duty to plaintiff given that plaintiff’s evidence, if credited by a jury, could easily establish that RIVERA V. CCA 3 CoreCivic failed to exercise reasonable care when its employees did not inform the Marshals of plaintiff’s prolonged detention, told plaintiff that he just needed to wait, implied that nothing could be done to trigger a hearing, and failed to inform him that he was in the legal custody of the Marshals and could request to speak with a deputy who was regularly at the detention center. The panel held that plaintiff had established a triable issue as to the elements of his false imprisonment and negligence claims. The record also showed that plaintiff established a triable issue as to each element of his claim for intentional infliction of emotional distress. A jury could reasonably find CoreCivic’s actions extreme or outrageous given the nature of plaintiff’s liberty interest, the egregious length of his detention without arraignment, the ease with which CoreCivic could have corrected the problem, and the callousness of its disregard.
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