Joseph Aluya v. Management & Training Corp.
671 F. App'x 970
| 9th Cir. | 2016Background
- Three inmates (Aluya, Hammond, Sutton) contracted Valley Fever while incarcerated at Taft Correctional Institute (TCI), operated by Management and Training Corporation (MTC).
- Inmates sued MTC for negligence and premises liability, alleging failure to reduce or warn about the risk of Valley Fever in an endemic area.
- The district court granted summary judgment for MTC, reasoning plaintiffs failed to show a higher infection rate at TCI than the surrounding community.
- Plaintiffs produced expert and other evidence identifying precautionary measures MTC could have taken and claiming its warnings and posted signs were inadequate.
- Plaintiffs sought liability based on MTC’s duty as the prison operator to protect incarcerated persons from known, concealed risks.
- The Ninth Circuit vacated and remanded, finding material factual disputes about breach and warning adequacy and rejecting the district court’s reliance on community infection-rate comparisons.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MTC owed a duty to undertake measures to reduce Valley Fever risk to inmates | MTC, as prison operator, had a duty to take reasonable measures to reduce known endemic risk arising from incarceration | MTC argued absence of evidence that infection rate at TCI exceeded the surrounding community defeats liability | Court: MTC had such a duty; similarity of community rates does not negate duty and does not preclude liability; issue of breach is for the jury |
| Whether lack of higher infection rate at TCI bars negligence liability | Plaintiffs: duty and breach focus on prison conditions and measures, not community-rate comparison | MTC: no higher rate means no actionable breach or causation | Court: rejected defendant’s reliance on community-rate parity as dispositive; summary judgment was improper |
| Whether MTC breached duty by failing to implement preventative measures | Plaintiffs: presented evidence of feasible measures MTC could have taken to reduce risk | MTC: argued no legal obligation to construct or alter facilities (and relied on community-rate defense) | Court: plaintiffs’ evidence created genuine dispute of material fact on breach; reserved for jury |
| Whether MTC’s warnings were adequate | Plaintiffs: warnings and signs were inadequate per expert evidence; Valley Fever is a hidden danger triggering a duty to warn | MTC: contended warnings and postings were sufficient | Court: adequacy of warnings was not addressed below; remanded for the district court to consider whether a factual dispute exists regarding adequacy of warnings |
Key Cases Cited
- Edison v. United States, 822 F.3d 510 (9th Cir. 2016) (prison operator/BOP duty to mitigate Valley Fever risk and limited role for negligence claims about construction)
- Ramirez v. Plough, Inc., 863 P.2d 167 (Cal. 1993) (standard that breach and factual disputes are for jury resolution)
- Rowland v. Christian, 443 P.2d 561 (Cal. 1968) (land possessor’s duty to warn of known concealed dangers)
VACATED AND REMANDED; costs awarded to appellants.