Hydrick v. Hunter
2012 U.S. App. LEXIS 628
| 9th Cir. | 2012Background
- Plaintiffs are civilly committed at Atascadero State Hospital under California's Sexually Violent Predator Act (Cal. Welf. & Inst. Code § 6600 et seq.).
- Plaintiffs sue hospital administrators and state officials under 42 U.S.C. § 1983 alleging constitutional rights violations from confinement conditions.
- District court denied defendants’ qualified-immunity motion for money damages; defendants appealed under the collateral-order doctrine.
- The prior Ninth Circuit decision (2007) partially reversed, granting immunity on some claims but not others; Supreme Court remanded post-Iqbal.
- On remand, court holds defendants are entitled to qualified immunity for money damages but plaintiffs may seek declaratory and injunctive relief.
- Conclusion: reverse and remand for litigation of declaratory/injunctive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants are entitled to qualified immunity for money damages | Hydrick contends claims allege conduct specifics. | Hydrick argues no plausible, non-conclusory facts show individual liability. | Yes, qualified immunity for money damages. |
| Whether plaintiffs may pursue declaratory and injunctive relief notwithstanding immunity | Plaintiffs seek ongoing relief regardless of money-damages immunity. | Immunity should bar only money damages, not declaratory/injunctive relief. | Yes, declaratory and injunctive relief may proceed. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading plausibility standard; personal liability requires plausible facts)
- Starr v. Baca, 652 F.3d 1202 (9th Cir. 2011) (deliberate indifference and supervisor liability standard informed by Iqbal)
- Morley v. Walker, 175 F.3d 756 (9th Cir. 1999) (collateral-order review of qualified-immunity rulings)
- Malik v. Brown, 16 F.3d 330 (9th Cir. 1994) (injunctive/declaratory-relief distinctions under immunity analysis)
- Los Angeles Police Protective League v. Gates, 995 F.2d 1469 (9th Cir. 1993) (immunity scope; distinguishes money damages from equitable relief)
- Center for Bio-Ethical Reform, Inc. v. Los Angeles County Sheriff Dept., 533 F.3d 780 (9th Cir. 2008) (immunity and remedies in § 1983 context)