Brown 235551 v. Maricopa, County of
2:24-cv-02282
| D. Ariz. | Aug 18, 2025Background
- Plaintiff, Jerry Douglas Harris Brown, Jr., a self-represented inmate, alleged denial of medical care while confined in Maricopa County Jail and later in Arizona State Prison Complex.
- Brown filed a civil rights action under 42 U.S.C. § 1983, asserting violations of his Eighth and Fourteenth Amendment rights related to alleged denial of medication and treatment for seizure-related injury.
- The district court had previously dismissed Brown’s original, first, and second complaints for failure to state a claim, granting leave to amend each time.
- Plaintiff’s Third Amended Complaint named Maricopa County, Correctional Health Services, former Sheriff Skinner, Jail Commander Patrick King, Captain King, and Sergeants Rogers and Kirk as defendants.
- The court conducted statutory screening under 28 U.S.C. § 1915A and dismissed the Third Amended Complaint and the action for failure to state a claim, also declining to exercise jurisdiction over state law claims.
- Plaintiff was denied further leave to amend after repeated failure to cure deficiencies identified by the court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Maricopa County is liable under § 1983 | County is liable for injuries caused by its agents | Liability requires a policy or custom causing injury | County not liable; no policy/custom alleged |
| Whether CHS is a proper defendant under § 1983 | Correctional Health Services is liable for denial | CHS is not a “person” under § 1983 | CHS not liable; not amenable to suit |
| Whether supervisory liability exists for individuals | Supervisors liable for acts of subordinates | No respondeat superior liability under § 1983 | No personal participation alleged; claims dismissed |
| Whether to exercise jurisdiction over state law claims | State tort and negligence claims arise from same facts | Should decline jurisdiction if federal claims dismissed | Court dismissed state law claims without prejudice |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (requires plausible factual allegations to state a claim)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (a claim must be plausible on its face)
- Monell v. Dept. of Soc. Servs., 436 U.S. 658 (1978) (local governments liable only for policies/customs, not vicarious liability)
- Rizzo v. Goode, 423 U.S. 362 (1976) (liability under § 1983 requires an affirmative link between injury and defendant’s actions)
- Haines v. Kerner, 404 U.S. 519 (1972) (self-represented pleadings are to be liberally construed)
- Erickson v. Pardus, 551 U.S. 89 (2007) (self-represented complaints held to less stringent standards)
- Hamilton v. Endell, 981 F.2d 1062 (9th Cir. 1992) (no supervisor liability under § 1983 without personal involvement)
- Taylor v. List, 880 F.2d 1040 (9th Cir. 1989) (respondeat superior does not apply in § 1983 actions)
- Sadoski v. Mosley, 435 F.3d 1076 (9th Cir. 2006) (municipal liability requires pleading of policy/custom connection)
- Moore v. Kayport Package Express, Inc., 885 F.2d 531 (9th Cir. 1989) (leave to amend not required if futile)
- Sisseton-Wahpeton Sioux Tribe v. United States, 90 F.3d 351 (9th Cir. 1996) (court has broad discretion to deny leave to amend after repeated failures)
- Ove v. Gwinn, 264 F.3d 817 (9th Cir. 2001) (court may decline supplemental jurisdiction after dismissal of federal claims)