Anthony Wright v. Paul Penzone
20-16275
| 9th Cir. | Mar 17, 2022Background
- Anthony Wright, a pretrial detainee indicted for felony murder of a police officer, was placed under a jail policy automatically housing such inmates in “Closed Custody.”
- In Closed Custody Wright was confined alone up to 23 hours per day and remained in that status for about 8.5 years; after a jury deadlocked at trial he was returned to general population while still indicted.
- Wright, proceeding pro se, sued under 42 U.S.C. § 1983 asserting: substantive and procedural due process violations from Closed Custody and deliberate indifference to medical needs (against jail medical director Alvarez); he also alleged harm from continuous lighting.
- The district court screened the complaint, allowed some claims to proceed, later granted summary judgment for most defendants, and dismissed the procedural due process claim; Wright appealed.
- The Ninth Circuit affirmed in part, reversed in part, and remanded: it allowed Wright’s Monell/official-capacity substantive-due-process claim against Sheriff Penzone to proceed, affirmed qualified immunity for the defendants in their personal capacities, affirmed summary judgment on the lighting and medical claims, and remanded the procedural-due-process claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prolonged Closed Custody amounted to unconstitutional punishment of a pretrial detainee | Wright: solitary for years caused psychological harm and was punitive | Defendants: conditions were security classification and not punishment; no harm beyond inherent confinement | Court: jury could find serious psychological harm; official-capacity Monell claim against Penzone may proceed (reversed as to SJ) |
| Whether defendants are entitled to qualified immunity in their personal capacities for placing Wright in Closed Custody | Wright: officers violated clearly established substantive-due-process rights | Defendants: law did not clearly establish that their specific conduct was unlawful | Court: affirmed qualified immunity for Penzone (personal), Vail, and Bailey; defendants entitled to qualified immunity |
| Whether continuous lighting violated substantive due process by causing harm beyond normal confinement discomforts | Wright: lighting caused permanent sight damage and sleep problems | Defendants: no objective evidence linking lighting to serious harm | Court: affirmed SJ for defendants; insufficient objective evidence of harm |
| Whether Wright was denied procedural due process in assignment to more restrictive conditions without procedural protections | Wright: he was housed in harsher conditions without formal hearing or process | Defendants: classification decisions are not constitutionally protected | Court: remanded procedural-due-process claim for district-court consideration under proper standard |
| Whether Alvarez was deliberately indifferent to Wright’s serious medical needs by refusing a lactose‑free diet | Wright: refusal and minimal recommendation (try Lactaid) amounted to deliberate indifference | Alvarez: actions at most negligent / difference of medical opinion | Court: affirmed SJ for Alvarez; conduct did not meet deliberate indifference standard |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (pretrial detainees may not be punished; test for when conditions constitute punishment)
- Demery v. Arpaio, 378 F.3d 1020 (9th Cir. 2004) (harm must significantly exceed inherent confinement discomforts)
- Monell v. Department of Social Servs., 436 U.S. 658 (municipal liability requires a policy, custom, or practice causing the deprivation)
- Hafer v. Melo, 502 U.S. 21 (official-capacity suits are against the governmental entity)
- Tolan v. Cotton, 572 U.S. 650 (2014) (summary-judgment review and qualified-immunity framework reminder)
- Kisela v. Hughes, 138 S. Ct. 1148 (2018) (do not define clearly established law at high level of generality)
- Castro v. County of Los Angeles, 833 F.3d 1060 (en banc) (deliberate indifference standard context for pretrial detainees)
- Gordon v. County of Orange, 888 F.3d 1118 (9th Cir. 2018) (deliberate indifference requires more than negligence)
- Sanchez v. Vild, 891 F.2d 240 (difference of medical opinion is not deliberate indifference)
- Montanye v. Haymes, 427 U.S. 236 (prisoners have no constitutional right to a particular security classification)
- Shorter v. Baca, 895 F.3d 1176 (9th Cir. 2018) (pretrial detainees have procedural-due-process rights before being placed in more severe conditions)