Hyde v. City of Wilcox, No. 21-15142 (9th Cir. 2022)
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Hyde, a 26-year-old with bipolar disorder, schizophrenia, and ADHD, took six prescription medications. After his arrest on suspicion of DUI, Hyde submitted to a blood draw. He tested negative for alcohol but positive for amphetamines, consistent with his prescriptions. After several hours without his medications, Hyde charged the door, fell, and injured his head. Hyde emerged from his cell calmly, then sprinted away. He reached a dead end, Officers deployed their Tasers multiple times, then tackled Hyde. After Hyde was in a restraint chair, Pralgo again used his Taser. Callahan-English used her arms to force Hyde’s head into a restraint hold. Minutes later Hyde rolled his head back, gasping for air, as officers passed by. He stopped breathing. Officers tried to revive him. Days later, Hyde died. Hyde’s causes of death included blunt force injuries, kidney damage caused by muscle breakdown, enlarged heart, and coronary artery atherosclerosis.
The Ninth Circuit affirmed in part the denial of a motion to dismiss a 42 U.S.C. 1983 suit. Officers Pralgo and Callahan-English used excessive force and violated clearly established law when they used a Taser and put Hyde in a head restraint after Hyde, handcuffed and shackled, posed no threat. Other officers reasonably used force when Hyde resisted. The complaint did not adequately allege that the officers knew of Hyde’s mental health condition or that he was in distress after the altercation; qualified immunity barred the claim that they violated Hyde’s right to adequate medical care. With respect to the failure-to-train and municipal liability claims, the court stated that an inadequate training policy itself cannot be inferred from a single incident.
Court Description: Civil Rights The panel affirmed in part and reversed in part the district court’s denial of a motion to dismiss a complaint brought pursuant to 42 U.S.C. § 1983 alleging, among other things, that law enforcement officers used excessive force on pretrial detainee Luke Hyde when they applied physical force and a Taser to subdue him and failed to provide him with adequate medical care. Hyde stopped breathing 21 minutes after being put in a restraint chair, and despite efforts by the officers to resuscitate him, he died five days later. Hyde’s parents sued on several theories under § 1983, including excessive force, failure to train, failure to supervise, failure to provide adequate medical care, and municipal liability. The district court held that the officers used unreasonable force and were not entitled to qualified immunity. * The Honorable Richard D. Bennett, United States District Judge for the District of Maryland, sitting by designation. HYDE V. CITY OF WILCOX 3 The panel affirmed the district court’s denial of the motion to dismiss for the excessive force claim against officers Pralgo and Callahan-English. The panel held that the two officers used excessive force and violated clearly established law when they used a Taser and put Hyde in a head restraint, even after Hyde—who had his hands handcuffed and legs shackled—had apparently stopped resisting and posed no threat. The panel reversed the denial of the motion to dismiss for the excessive force claim as to the other officer defendants, determining that they had reasonably used force earlier in the altercation when Hyde resisted prior to being subdued and restrained. The panel also reversed the district court’s denial of dismissal on the claim that Hyde was denied adequate medical care. The panel determined that the complaint had not adequately alleged that the named officers knew of Hyde’s mental health condition or that he was in distress after the altercation. The panel therefore held that qualified immunity barred the claim that individual officers violated Hyde’s right to adequate medical care. Finally, reviewing under pendent jurisdiction the district court’s denial of the motion to dismiss the claims against the municipal defendants, the panel reversed on the failure-to- train and municipal liability claims. The panel stated that while deliberate indifference can be inferred from a single incident when “the unconstitutional consequences of failing to train” are “patently obvious,” an inadequate training policy itself cannot be inferred from a single incident. 4 HYDE V. CITY OF WILCOX
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