Maria Flores v. County of Los Angeles
2014 U.S. App. LEXIS 13318
9th Cir.2014Background
- Maria Flores alleges an unidentified Los Angeles County deputy (Deputy Doe 1) sexually fondled her without consent at a county vehicle inspection area after she went to clear a traffic ticket in 2011.
- Flores sued Los Angeles County and Sheriff Lee Baca under 42 U.S.C. § 1983, asserting Monell liability for failure to train deputies to avoid sexually assaulting women; she named state-law claims and Doe defendants as well.
- FAC alleged inadequate training and pointed to a prior deputy’s 2004–2005 sexual assaults and conviction (conviction occurred before Flores’s 2011 incident) as putative notice to defendants.
- The district court dismissed the § 1983 Monell and related claims for failure to state a claim (Rule 12(b)(6)), concluding Flores did not plead deliberate indifference or a causal connection; dismissal was with prejudice as to those claims.
- On appeal, Flores argued the prior conviction and omissions in the Sheriff’s Department Manual sufficiently alleged deliberate indifference and causation; the Ninth Circuit affirmed dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether County/Baca can be liable under § 1983 for failure to train re: deputies committing sexual assaults | Flores: prior deputy convictions and absence of anti-assault language in manual put County/Baca on notice and show deliberate indifference | County/Baca: isolated prior conviction and omission from manual do not show a pattern or that the risk was known or obvious; criminal prohibition already existed | Held: No Monell liability — plaintiff failed to plausibly plead deliberate indifference or causation |
| Whether a single prior deputy’s criminal conduct suffices to establish a pattern for deliberate indifference | Flores: prior convictions evidence notice of training deficiencies | Defendants: single offender, not at same site, does not establish a pattern of violations | Held: Single isolated offender insufficient; no pattern alleged |
| Whether the alleged omission (no express manual language forbidding sexual assault) can alone show deliberate indifference in a “narrow” obvious-risk exception | Flores: explicit manual rules would have prevented the assault and show policy choice | Defendants: sexual assault is clearly criminal; employees are presumed to know the law, so omission is not a patently obvious risk requiring municipal training | Held: Narrow exception inapplicable — risk not so patently obvious; omission implausible as basis for deliberate indifference |
| Whether Flores’s complaint met Iqbal plausibility standards for a free‑standing failure‑to‑train claim | Flores: factual allegations and proposed manual language suffice | Defendants: allegations are conclusory and speculative; do not show causal link or deliberate indifference | Held: Complaint fails Iqbal plausibility; dismissal affirmed |
Key Cases Cited
- Monell v. Dep’t of Soc. Serv. of the City of New York, 436 U.S. 658 (municipal liability requires an official policy or custom)
- City of Canton v. Harris, 489 U.S. 378 (municipal failure to train actionable only if it evidences deliberate indifference)
- Connick v. Thompson, 563 U.S. 51 (plaintiff must show municipality disregarded known or obvious consequences of training omission)
- Ashcroft v. Iqbal, 556 U.S. 662 (complaint must state plausible claim; conclusory allegations insufficient)
- Price v. Sery, 513 F.3d 962 (9th Cir.) (requirement that plaintiff show conscious or deliberate choice for failure‑to‑train claim)