Miranda-Rivera v. Toledo-Davila, 813 F.3d 64

Background

On April 10, 2007, PRPD officers Pérez and Rivera stopped Christopher Rojas for dangerous driving; during the encounter he became agitated, screamed that someone was trying to kill him, and resisted getting into the patrol car and holding cell while handcuffed.
Officers transported Rojas to the police station; at the station they restrained him face-down on the cell floor with wrists handcuffed behind his back and tie-wraps on his ankles; Rojas became increasingly purple, then unresponsive; paramedics pronounced him dead shortly after arrival.
Autopsy listed cause of death as bodily trauma and cocaine intoxication (manner: accident); photos and medical opinions showed multiple external injuries and subarachnoid hemorrhage; parties disputed whether trauma or cocaine caused death.
Plaintiffs (family and estate) sued under 42 U.S.C. § 1983 for excessive force and denial of medical care against Officers Pérez and Rodríguez and supervisory claims against Superintendent Toledo; district court granted summary judgment for defendants on these claims and dismissed supplemental state claims.
The First Circuit reversed in part and remanded: it held summary judgment improper on excessive force and denial-of-medical-care claims against Pérez and Rodríguez (and failure-to-intervene against Rodríguez), but affirmed dismissal of supervisory claims against Toledo and ordered reinstatement of Puerto Rican law claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force by Officer Pérez while transporting/detaining Rojas	Pérez used excessive, unnecessary force after Rojas was restrained, causing severe injuries and death	Force used was reasonable to subdue and transport a resisting, erratic arrestee; insufficient evidence of excessive force	Reversed as to Pérez; genuine dispute of material fact exists and qualified immunity denied on these facts
Failure to intervene by Sgt. Rodríguez	Rodríguez observed force at station and failed to stop it	Rodríguez did not touch Rojas and arrived after earlier struggle; no opportunity to prevent earlier force	Reversed and remanded as to Rodríguez for possible failure-to-intervene liability for force observed at station
Denial of medical care by Pérez and Rodríguez	Officers were deliberately indifferent to obvious, serious medical need (Rojas’s appearance/symptoms) and delayed/failed to obtain treatment	Officers reasonably chose to take Rojas to station and called paramedics when concerned; insufficient evidence of deliberate indifference	Reversed and remanded: jury could find serious need and deliberate indifference; qualified immunity denied
Supervisory liability of Superintendent Toledo	Plaintiffs argued supervisory responsibility/ratification or failure to train/supervise	Complaint lacked factual allegations about Toledo’s conduct, training, or policies; Plaintiffs raised new theories late	Affirmed: pleading inadequate for supervisory liability; failure-to-train theory properly rejected as unpled

Key Cases Cited

Graham v. Connor, 490 U.S. 386 (use of force by arrestees analyzed under objective reasonableness)
Kingsley v. Hendrickson, 135 S. Ct. 2466 (pretrial detainee excessive-force claims judged by objective reasonableness)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-step framework)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard; awareness of substantial risk)
City of Revere v. Mass. Gen. Hosp., 463 U.S. 239 (duty to provide medical care to persons injured while apprehended)
Gaudreault v. Municipality of Salem, 923 F.2d 203 (First Circuit on deliberate indifference and timing of intervention)
Wilkins v. Gaddy, 559 U.S. 34 (serious injury is probative but not required for excessive-force claim)