Lapachet v. Cal. Forensic Med. Grp., Inc.
313 F. Supp. 3d 1183
E.D. Cal.2018Background
- Plaintiff Jeremy Lapachet entered Stanislaus County Jail able-bodied on Dec. 9, 2014; by Oct. 26, 2015 he left paralyzed after events while in custody following ingestion of an unknown substance.
- Over ~32 hours after being placed in a "Sobering Cell," multiple CFMG (private medical) and County staff documented elevated vitals, restlessness, self-harm, bleeding, and ultimately found plaintiff prone and barely responsive before transfer to hospital.
- Complaint alleges deliberate indifference to serious medical needs (Eighth Amendment § 1983), a Monell claim against Stanislaus County, supervisory liability and state-law claims including Bane Act, Cal. Gov. Code § 845.6, and negligence; some causes were previously stipulated or separately moved.
- Defendants moved to dismiss several causes of action and specific defendants (notably Sheriff Christianson and the County) for failure to plead facts showing personal involvement or overcoming statutory immunities.
- The Court dismissed multiple claims as to Sheriff Christianson for lack of factual allegations of his personal participation, dismissed the Second and Sixth causes in full, denied dismissal of Monell claim against County, and dismissed the County Bane Act and negligence claims based on governmental immunity (§ 844.6). Several dismissals were with leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sheriff Christianson is liable under § 1983 for Eighth Amendment deliberate indifference | Christianson (supervisor) knew or should have known of plaintiff's medical emergency and thus is liable | Complaint lacks any factual allegations showing Christianson’s personal involvement or notice | Dismissed as to Christianson for lack of factual allegations; leave to amend granted |
| Whether Monell claim against County survives dismissal | County maintained unconstitutional policies/customs (failure to classify, monitor, house at-risk inmates) causing injury | County argued insufficient pattern/custom allegations to state a Monell claim | Denied as to County — complaint plausibly alleges policies/customs with factual support |
| Whether Bane Act claim (Cal. Civ. Code § 52.1) requires independent threats/coercion beyond alleged deliberate indifference | Bane Act covers deliberate indifference to serious medical needs where conduct is coercive or threatening | County and Christianson argue Bane Act requires threats/intimidation separate from the constitutional violation; County also asserted statutory immunity § 844.6 | Bane Act claim dismissed as to Christianson for lack of allegations; Bane Act claim against County dismissed on immunity grounds (§ 844.6) |
| Whether § 845.6 (failure to summon medical care) and negligence claims survive | Plaintiff contends staff failed to summon appropriate care or adequate safety measures after intoxication/self-harm signs | Defendants argue medical care/monitoring was summoned and § 844.6 bars County negligence claims | § 845.6 and negligence claims against County dismissed (medical care was summoned and immunity applies); § 845.6 dismissed with leave to amend; negligence vs. Christianson dismissed for lack of factual allegations |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
- Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (municipal liability requires policy, custom, or final policymaker)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; no mere conclusory allegations)
- Jett v. Penner, 439 F.3d 1091 (9th Cir.) (two-part deliberate indifference test)
- Farmer v. Brennan, 511 U.S. 825 (subjective knowledge for Eighth Amendment culpability)
- Connick v. Thompson, 563 U.S. 51 (municipal failure-to-train standards)
- Starr v. Baca, 652 F.3d 1202 (supervisory liability standards under § 1983)
- Krainski v. Nevada ex rel. Bd. of Regents, 616 F.3d 963 (conclusory supervisory allegations insufficient)
- Reese v. County of Sacramento, 888 F.3d 1030 (Bane Act — no need for coercion independent of constitutional violation)