M.H. v. County of Alameda
62 F. Supp. 3d 1049
N.D. Cal.2014Background
- Martin Harrison died in Alameda County jail while in custody; plaintiffs are his children bringing §1983, Bane Act, and common-law claims against Sheriff’s deputies, Alameda County, Corizon Health, and individuals.
- Harrison was arrested August 13, 2010, after alleged alcohol-related issues; initial medical screening by Nurse Sancho at Glenn Dyer Detention Facility noted alcohol history but CIWA was crossed out.
- Harrison was transferred to Santa Rita Jail then placed in an isolation cell after displaying bizarre behavior and disorientation; CJMH referral and delayed mental-health/medical evaluation followed.
- Deputies conducted a struggle with Harrison during an attempted transfer or containment; Tasers and physical force were used; Harrison was moved to hallway for evaluation and later taken to hospital, where he died.
- Corizon, Dr. Orr, and Nurse Sancho disputed screening adequacy, training, and supervision; plaintiffs rely on expert opinions to claim deliberate indifference and policy failures.
- The Amended Order grants partial summary judgment to some defendants while denying others on multiple counts, including deliberate indifference, Monell claims, and the 845.6 and Bane Act theories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference to serious medical needs by individual defendants | Harrison’s withdrawal risk and DTs were evident; Sancho failed to initiate CIWA and Hast failed timely CJMH intervention. | Sancho lacked subjective awareness of withdrawal risk; Ahlf lacked knowledge of alcoholism; Hast argues triage duties. | Genuine disputes remain; Sancho and Hast denied summary judgment; Ahlf granted on some grounds; overall issue for trial. |
| Monell liability for County and Corizon related to training and policies on alcohol withdrawal | County/Corizon failed to train staff and implement NCCHC standards, causing deliberate indifference. | Training efforts and adherence to policies contested; lack of pattern evidence. | Monell claims proceed for training deficiencies against County and Corizon; use-of-force Monell claim against County granted partial summary judgment. |
| Supervisory liability of Dr. Orr | Orr's policy decisions and ratification of practices caused constitutional violations. | No direct causal link established; policy disagreements. | Court denies summary judgment for Orr on supervisory liability. |
| Excessive force by deputies; qualified immunity | Totality of force (Taser, strikes, restraints) was excessive and not necessary. | Fact-intensive; varying accounts; some force may have been warranted. | Summary judgment denied for excessive force claims against Deputies; questions of fact for trial; qualified immunity denied for deputies. |
| California Government Code § 845.6—duty to summon medical care | Deputy Ahlf’s failure to summon care after recognizing risk; Hast not summoning medical care. | 845.6 limited to failure to summon for serious obvious conditions; Hast not liable for diagnosis/treatment failures. | §845.6 claim against Ahlf viable; Hast entitled to summary judgment on §845.6. |
Key Cases Cited
- Gibson v. Cnty. of Washoe, 290 F.3d 1175 (9th Cir. 2002) (deliberate indifference may be shown by circumstantial evidence; nurse awareness of risk matters)
- Tsao v. Desert Palace, Inc., 698 F.3d 1128 (9th Cir. 2012) (policies vs. inaction; deliberate indifference under Monell)
- Long v. Cnty. of Los Angeles, 442 F.3d 1178 (9th Cir. 2006) (failure to train may be Monell basis when adequate training is deficient)
- Brown v. Board of County Comm'rs of Bryan Cnty., 520 U.S. 397 (1997) (pattern of violations; failure to train is actionable policy under §1983)
- Lolli v. County of Orange, 351 F.3d 410 (9th Cir. 2003) (plaintiff may prove excessive force without identifying each officer's specific act)
- Graham v. Connor, 490 U.S. 386 (1989) (reasonableness of use of force under totality of circumstances)
- Jett v. Penner, 439 F.3d 1091 (9th Cir. 2006) (deliberate indifference standard appropriate for medical needs in detention)