Jonathon Castro v. County of Los Angeles
2015 U.S. App. LEXIS 14132
9th Cir.2015Background
- Jonathan Castro was arrested for public intoxication and placed in a fully walled "sobering cell" at LASD West Hollywood Station; another arrestee, Jonathan Gonzalez, described as "combative," was later placed in the same cell.
- After Gonzalez was placed in the cell, Castro pounded on the cell door for about a minute with no response; later a volunteer observed inappropriate touching, and several minutes after that Gonzalez assaulted Castro, leaving him with a broken jaw and traumatic brain injury requiring long-term care.
- Castro sued under 42 U.S.C. § 1983 and state law against the County, the Sheriffs’ Department, and two officers (Solomon and Valentine). A jury found for Castro and awarded over $2.6 million; punitive damages were later stipulated in specified amounts for the officers and attorneys’ fees were awarded.
- The district court denied renewed JMOL; on appeal the Ninth Circuit affirmed liability as to the individual officers (denying qualified immunity) but reversed as to municipal (County) liability (Monell). The judgment against the County was vacated for lack of evidence that the County had actual knowledge of the specific risk.
- Key factual/legal bases at trial: video and witness testimony about unheeded banging; evidence that policies/regulations required audio monitoring in sobering cells (California building code); lack of evidence that the County had been notified it was out of compliance or had actual knowledge of the regulatory risk.
Issues
| Issue | Castro's Argument | County/Officers' Argument | Held |
|---|---|---|---|
| Whether individual officers are entitled to qualified immunity for failure-to-protect (deliberate indifference) | Solomon/Valentine ignored obvious risk (banging, volunteer report, Gonzalez’s combative status) and thus acted with deliberate indifference | Officers claimed they did not hear/know of danger and thus lacked subjective awareness; sought qualified immunity | Affirmed against officers: jury had sufficient evidence to find subjective awareness and deliberate indifference; qualified immunity denied |
| Whether punitive damages required additional proof beyond deliberate indifference | Castro: deliberate indifference suffices; jury may impose punitive damages when conduct shows reckless/callous indifference | Defendants: evidence insufficient to support punitive damages | Affirmed: jury reasonably found reckless or callous indifference once deliberate indifference was proven |
| Whether the County is liable under Monell for jail design or practice that caused the violation | Castro: jail design (sobering cell lacking audio monitoring) is a formal municipal policy/choice and County knew of regulatory risk; thus Monell liability | County: Eleventh Amendment, lack of pattern (single incident), design is not a "policy," and no evidence County had actual knowledge of the regulatory risk | Reversed as to County: court held jail design can be a formal policy, but plaintiff failed to prove actual municipal knowledge of the specific risk (only constructive knowledge from regulations), so no Monell liability |
| Standard for pretrial detainee failure-to-protect claims post-Kingsley | Castro: (and majority) Farmer deliberate-indifference test (subjective knowledge) governs; Kingsley does not change failure-to-protect standard | Defendants (and concurrence/dissent debate): Kingsley may require objective test for Fourteenth Amendment claims | Majority: Clouthier/Farmer subjective deliberate-indifference standard remains controlling for failure-to-protect; dissent argues Kingsley calls that into question but panel follows precedent |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (establishes deliberate-indifference standard for failure-to-protect claims)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires an official policy or custom)
- Pembaur v. City of Cincinnati, 475 U.S. 469 (1986) (a municipality acts through deliberate choices of policymakers; formal policy concept)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity doctrine)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-prong analysis)
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainee constitutional protections and relation to punishment standard)
- Scott v. Harris, 550 U.S. 372 (2007) (limits on disregarding video evidence on appeal)