Danielle Garcia v. Dr. Charles Li
689 F. App'x 946
| 11th Cir. | 2017Background
- Danielle Garcia, pro se, sued a state judge (Judge Kathryn Schrader), Gwinnett County Sheriff, Georgia Regional Hospital director Dr. Charles Li, Corizon Health (county medical contractor), and three public defenders (Whitman, Fluker, Dillon) under 42 U.S.C. § 1983 and other federal law alleging constitutional violations arising from her state criminal proceedings for aggravated assault.
- A public defender (Whitman) moved for a competency evaluation (initially without Garcia's consent); Judge Schrader ordered evaluations at Georgia Regional Hospital and later found Garcia competent to stand trial. Garcia was later confined at the county detention center and re-evaluated at the hospital after a hunger strike.
- Garcia alleges denial of access to legal materials, solitary confinement, harassment, and that public defenders entered a NGRI plea and failed to challenge competency evidence; the state court ultimately dismissed the assault charge and Garcia was released.
- Garcia filed this federal suit alleging constitutional violations by the judge, hospital director, sheriff, Corizon, and her public defenders; the district court dismissed her complaint under 28 U.S.C. § 1915(e)(2)(B)(ii) for failure to state a claim.
- The Eleventh Circuit affirmed, concluding federal courts lacked jurisdiction to review state-court orders under Rooker–Feldman as to the judge and that Garcia failed to plead facts sufficient to hold the hospital director, sheriff, Corizon, or public defenders liable under § 1983.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal courts can review and void state-court contempt and competency orders by Judge Schrader | Garcia sought relief effectively declaring Judge Schrader's contempt and competency orders unconstitutional and expunging them | State-court judgments preclude lower federal court review under Rooker–Feldman | Rooker–Feldman bars federal review; court lacked jurisdiction over claims against Judge Schrader |
| Whether Dr. Li (hospital director) is liable under § 1983 for hospital employees' alleged misconduct | Garcia alleged Dr. Li ignored a grievance and was connected via hospital evaluations / policies | Supervisory liability requires personal participation or a causal link (widespread abuse or policy) beyond respondeat superior | Dismissed: Garcia failed to allege Dr. Li’s personal involvement or causal connection sufficient for § 1983 liability |
| Whether Sheriff Conway can be held liable under § 1983 for detention center conditions/actions | Garcia alleged constitutional deprivations at the detention center under Conway’s command | Liability requires personal participation or a sufficient causal connection between sheriff’s actions/policies and the harm | Dismissed: no facts pleaded showing Conway’s personal involvement or causal link |
| Whether Corizon (private contractor) can be liable as a municipal equivalent for employees’ actions | Garcia alleged Corizon employees denied legal access, isolated her, and harassed her; implied a company policy or directives | A private contractor furnishing core state functions can be liable, but plaintiff must show a policy/practice or final policymaker action producing the violation | Dismissed: allegations did not plausibly show a Corizon policy/practice or final policymaker decision causing constitutional violations |
| Whether public defenders (Whitman, Fluker, Dillon) acted under color of state law and are § 1983 liable; sufficiency of conspiracy claim | Garcia contended her defenders violated constitutional rights by seeking competency evaluations, entering NGRI plea, failing to challenge evidence, and conspiring with others | Public defenders performing traditional defense functions do not act under color of state law; conspiracy claims require factual support beyond conclusory allegations | Dismissed: public defenders not liable for traditional lawyering under § 1983; conspiracy claim was conclusory and failed Rule 8 plausibility pleading |
Key Cases Cited
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (federal courts cannot act as appellate courts over state-court judgments)
- Dist. of Columbia Ct. of App. v. Feldman, 460 U.S. 462 (federal jurisdictional bar to reviewing state-court judgments concerning state court proceedings)
- Alvarez v. Att’y Gen. for Fla., 679 F.3d 1257 (11th Cir. 2012) (defines scope of Rooker–Feldman)
- Cottone v. Jenne, 326 F.3d 1352 (11th Cir. 2003) (supervisory liability under § 1983 requires personal participation or causal connection)
- Craig v. Floyd County, 643 F.3d 1306 (11th Cir. 2011) (private contractors providing inmate medical care can be municipal-equivalents under § 1983)
- Holloman ex rel. Holloman v. Harland, 370 F.3d 1252 (11th Cir. 2004) (standards for municipal/policymaker liability)
- Polk County v. Dodson, 454 U.S. 312 (public defenders performing traditional functions do not act under color of state law for § 1983)
- Wahl v. McIver, 773 F.2d 1169 (public defender liability when conspiring with state actors can expose them to § 1983 liability)
- Ashcroft v. Iqbal, 556 U.S. 662 (conclusory allegations inadequate; pleading must show plausible entitlement to relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard: labels and conclusions insufficient)