Lecia Shorter v. Leroy Baca, 895 F.3d 1176

Background

Shorter, a pretrial detainee with a diagnosed mood disorder, was housed in Los Angeles County’s high-observation housing (HOH) at CRDF for 32 days in 2011 and subjected to more restrictive conditions than general population inmates.
HOH practices included routine shackling for recreation (women cuffed to steel tables in an indoor dayroom), frequent denial of showers, recreation, and meals (logs showed multiple days with missed showers/meals), and visual body-cavity searches after court returns.
Noncompliant detainees were often left unclothed and chained to cell doors for hours without food, water, or toilet access; deputies testified they were trained to do so in some instances.
Shorter required regular anticoagulation monitoring (Coumadin); jail tested her once, stopped the medication for "dangerously thin" result, and did not re-test while detained; post-release testing showed blood too thick.
Procedurally: County defendants won partial summary judgment on the inadequate medical-care claim; remaining claims went to jury, which returned verdict for defendants after the magistrate judge instructed the jury to "give deference to jail officials." Shorter appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriateness of Norwood deference instruction for conditions of confinement	Norwood instruction improperly told jury to defer where evidence showed deprivation resulted from overcrowding/understaffing and was unnecessary	Deference is appropriate to respect corrections expertise in maintaining security	Court: Norwood instruction ordinarily should not be given when sole justification is overcrowding/understaffing; error to give it here
Appropriateness of deference instruction for excessive-search (shackling/unclothed detainees) claim	Shackling noncompliant detainees to cell doors unclothed for hours was punitive, unnecessary, and lacked legitimate penological justification	County claimed security needs but offered no specific penological basis for the practice	Court: Substantial evidence showed the practice was unjustified; deference was not warranted and instruction was erroneous
Procedural due process re: mental-health classification into HOH	Shorter lacked opportunity/process to challenge HOH classification; jail failed to provide grievance forms and screening was cursory	County argued classification procedures were sufficient and review not required	Court: Denial of new trial was abuse of discretion; verdict against weight of evidence—new trial required on misclassification claim
Adequacy-of-medical-care standard applied at summary judgment	Shorter argued Fourteenth Amendment objective deliberate-indifference standard applies to pretrial detainees	County relied on Eighth Amendment subjective deliberate-indifference standard at summary judgment	Court: Vacated partial summary judgment and remanded for proceedings consistent with Gordon (Fourteenth Amendment objective standard)

Key Cases Cited

Monell v. Department of Social Services, 436 U.S. 658 (municipal liability requires policy or custom)
Bell v. Wolfish, 441 U.S. 520 (pretrial detainee conditions analyzed under Due Process; punishment inquiry)
Florence v. Board of Chosen Freeholders, 566 U.S. 318 (deference to correctional officials for certain strip searches on security grounds)
Norwood v. Vance, 591 F.3d 1062 (Ninth Circuit precedent discussing jury deference instruction)
Byrd v. Maricopa Cty. Sheriff’s Dep’t, 629 F.3d 1135 (en banc; unreasonable strip searches not entitled to deference)
Gordon v. County of Orange, 888 F.3d 1118 (Fourteenth Amendment objective deliberate-indifference standard for pretrial detainee medical-care claims)
Block v. Rutherford, 468 U.S. 576 (courts ordinarily defer to prison officials absent substantial evidence officials exaggerated response)
Pierce v. County of Orange, 526 F.3d 1190 (prisoners retain right to exercise; limits on deprivation)
Spain v. Procunier, 600 F.2d 189 (right to outdoor exercise for segregated inmates)