Ana Sandoval v. County of San Diego
985 F.3d 657
| 9th Cir. | 2021Background
- Ronnie Sandoval ingested a large quantity of methamphetamine before arrest; at booking deputies observed sweating, disorientation, lethargy, and urged further medical evaluation.
- Nurse Romeo de Guzman performed a very brief blood‑sugar check, placed Sandoval in Medical Observation Cell No. 1 (MOC1), and did not recheck him or notify the night shift; MOC1 was a “mixed‑use” cell with only verbal pass‑offs.
- Sandoval was largely unmonitored for ~8 hours; shortly after 12:55 a.m. officers found him unresponsive and seizing. Nurse Dana Harris became team leader but initially summoned EMTs (not paramedics) and, according to some witnesses, refused repeated requests to call 9‑1‑1; paramedics arrived ~47 minutes after the seizure was first observed.
- EMTs were unable to transport an unresponsive patient; Sandoval lost his pulse during transfer and died. Plaintiff Ana Sandoval sued Nurses de Guzman, Harris, Llamado and the County under 42 U.S.C. § 1983 (Fourteenth Amendment inadequate medical care) and state law.
- The district court granted summary judgment for defendants and sustained unexplained evidentiary objections; the Ninth Circuit held the evidentiary ruling was an abuse of discretion, applied the post‑Kingsley/Gordon objective standard for pretrial detainee medical claims, reversed summary judgment as to the nurses and the County, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Governing constitutional standard for pretrial detainee medical claims | Gordon/Castro: Fourteenth‑Amendment claims use an objective unreasonableness test | Pre‑Gordon precedent required subjective deliberate indifference | Court: Gordon objective framework governs the merits; district court erred applying subjective standard |
| Individual nurses’ liability (de Guzman, Harris, Llamado) | Nurses’ conduct (no monitoring, minimal exam, refusing paramedics) was objectively unreasonable and caused death | Actions were reasonable medical judgments or lacked required subjective awareness | Court: Triable issues of fact exist for each nurse under the Gordon objective test; summary judgment improper |
| Qualified immunity for individual nurses | Plaintiff: law was clearly established such that a reasonable nurse would know the conduct was unlawful | Nurses: at time of conduct (2014) law required subjective awareness; they are entitled to immunity | Court: Apply current objective standard to merits and assess clearly‑established law objectively (Horton approach); reasonable officials had fair notice; qualified immunity denied on summary judgment |
| County (Monell) liability for MOC1 practices | County’s mixed‑use MOC1, reliance on verbal pass‑offs and lack of logs caused confusion and foreseeable risk; custom/policy caused death | County: no deliberate indifference; no prior injuries to show practice was substantially certain to cause constitutional violations | Court: Sufficient circumstantial evidence to create triable issue on Monell deliberate indifference; summary judgment improper |
| District court’s exclusion of key evidence | Excluded police reports, expert report, procedures after boilerplate objections—Plaintiff could present admissible content at trial | Defendants argued objections (relevance/hearsay/foundation) supported exclusion | Court: District court abused discretion; boilerplate objections meritless and evidence considered on appeal |
Key Cases Cited
- Gordon v. County of Orange, 888 F.3d 1118 (9th Cir. 2018) (adopted objective deliberate‑indifference standard for pretrial detainee medical claims)
- Kingsley v. Hendrickson, 576 U.S. 389 (2015) (Fourteenth‑Amendment excessive‑force claims judged by objective unreasonableness)
- Castro v. County of Los Angeles, 833 F.3d 1060 (9th Cir. 2016) (applied objective framework to failure‑to‑protect claims; guided later extension to medical claims)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference to serious medical needs)
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainees’ rights derive from Fourteenth Amendment Due Process)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires awareness of substantial risk)
- Peralta v. Dillard, 744 F.3d 1076 (9th Cir. 2014) (discussion of subjective deliberate indifference standard)
- Horton by Horton v. City of Santa Maria, 915 F.3d 592 (9th Cir. 2019) (qualified immunity analysis when governing law changes—focus on objective aspects of clearly established law)
- Estate of Ford v. Ramirez‑Palmer, 301 F.3d 1043 (9th Cir. 2002) (distinguishing merits and qualified‑immunity inquiries; objective component matters)
- Monell v. Dept. of Soc. Servs., 436 U.S. 658 (1978) (municipal liability for unconstitutional policy or custom)
- Lemire v. Cal. Dep’t of Corr. & Rehab., 726 F.3d 1062 (9th Cir. 2013) (failure to provide life‑saving measures can support deliberate indifference)
- Jett v. Penner, 439 F.3d 1091 (9th Cir. 2006) (denial, delay, or interference with needed treatment violates the Constitution)
- Clement v. Gomez, 298 F.3d 898 (9th Cir. 2002) (delay in decontamination/medical care after pepper spray can constitute constitutional violation)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework)