Darling v. Los Angeles County Sheriff's Department
695 F. App'x 216
| 9th Cir. | 2017Background
- Rosyln Darling (aka Robin Hughes) sued under 42 U.S.C. § 1983 after arrests and detention arising from a domestic dispute with her roommate, alleging multiple constitutional violations.
- The district court dismissed several claims on Rule 12(b)(6) grounds and granted summary judgment on others; Darling appealed pro se to the Ninth Circuit.
- Key claims asserted: inadequate medical care and unconstitutional jail conditions, equal protection (gender discrimination), excessive force, Fourth Amendment unlawful arrest (June 2010), false arrest and malicious prosecution (August 2010), and excessive bail.
- The district court also denied Darling discovery-extension and recusal requests; she challenged those denials on appeal.
- The Ninth Circuit reviewed dismissal and summary judgment de novo and affirmed in all respects, rejecting additional allegations of judicial misconduct and denying mediation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference (medical care/conditions) | Darling claimed jail officials ignored risks to her health/safety | Defendants lacked awareness or did not disregard any serious risk | Dismissed — pleading failed to show defendants knew of and disregarded risk |
| Equal protection (gender discrimination) | Darling alleged discriminatory treatment based on gender | Defendants acted without discriminatory intent | Dismissed — no facts showing intentional gender-based discrimination |
| Excessive force | Darling alleged officers used unconstitutional force during detention/arrest | Use of force was reasonable under the circumstances | Dismissed — allegations insufficient to show objectively unreasonable force |
| Fourth Amendment (June 2010 arrest) | Arrest lacked probable cause | Officers had objective probable cause for the arrest | Dismissed — plaintiff did not allege lack of probable cause |
| False arrest / Malicious prosecution (Aug 2010) | Darling argued arrests and prosecution lacked probable cause and were malicious | Probable cause existed; thus no unlawful arrest or malicious prosecution | Summary judgment for defendants — no genuine dispute that probable cause existed |
| Excessive bail | Darling claimed defendants misled judicial officer to obtain excessive bail | Defendants did not deliberately or recklessly mislead the judge | Summary judgment for defendants — no evidence of deliberate or reckless misleading |
| Discovery extension & recusal requests | Darling sought more discovery time and judge recusal | No good cause for schedule modification; no grounds for recusal | Denials upheld — no abuse of discretion |
Key Cases Cited
- Foster v. Runnels, 554 F.3d 807 (9th Cir. 2009) (elements of deliberate indifference to inmate health or safety)
- Lolli v. County of Orange, 351 F.3d 410 (9th Cir. 2003) (pretrial detainee medical claims analyzed under Fourteenth Amendment)
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (standard for excessive force by pretrial detainees)
- Dubner v. City & Cty. of San Francisco, 266 F.3d 959 (9th Cir. 2001) (plaintiff must allege absence of probable cause for § 1983 unlawful arrest claim)
- Lacey v. Maricopa County, 693 F.3d 896 (9th Cir. 2012) (elements of malicious prosecution under § 1983)
- Galen v. County of Los Angeles, 477 F.3d 652 (9th Cir. 2007) (requirements for excessive bail claim involving alleged misleading of judicial officers)
- Lee v. City of Los Angeles, 250 F.3d 668 (9th Cir. 2001) (equal protection requires discriminatory intent)