Miriam Mendiola-Martinez v. Joseph Arpaio
2016 U.S. App. LEXIS 16666
| 9th Cir. | 2016Background
- Miriam Mendiola-Martinez, arrested while six months pregnant for nonviolent offenses, was in Maricopa County Sheriff’s Office (MCSO) custody when transported to and treated at Maricopa Medical Center for labor and delivery in December 2009; she delivered by C-section and was released days later.
- MCSO had a written Restraint Policy requiring restraints for inmates during transport and at hospitals, with a limited exception when medical staff required removal; days before the birth MCSO issued an "active-labor" memorandum advising removal of restraints during active labor or when a doctor ordered it.
- Mendiola-Martinez alleges she was shackled during at least one ambulance trip while in labor, was placed on a tether to the hospital bed during post-op recovery, and later was handcuffed and chained while leaving the hospital; she also alleges denial of adequate pregnancy nutrition and of a breast pump.
- She sued Maricopa County, Sheriff Arpaio (official capacity), the Maricopa County Special Health Care District/Medical Center, and unnamed individuals under 42 U.S.C. §§ 1981 & 1983 asserting Eighth Amendment (deliberate indifference/cruel and unusual punishment), Monell municipal liability, and equal protection claims.
- The district court granted summary judgment for the County Defendants and the Medical Center and taxed costs against plaintiff; the Ninth Circuit reviews the summary judgment de novo and cost awards for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether shackling a woman in labor violates the Eighth Amendment / Monell liability for MCSO policy | Mendiola-Martinez: shackling during labor exposed her to a substantial risk of serious harm and MCSO policy caused it | County: restraints are routine security measures justified to prevent flight/ensure safety; policy permitted medical removal | Vacated in part: factual disputes (e.g., whether she was shackled in second transport) preclude summary judgment; remanded for jury on shackling during labor and shackling while leaving hospital; Monell claim likewise remanded as to those incidents |
| Whether postpartum tethering (post‑C‑section) violated Eighth Amendment | Plaintiff: tether aggravated incision, impeded recovery and increased risk (e.g., DVT/fall) | County: tether allowed ambulation; designed to mitigate risks while maintaining security | Affirmed for County on tether during recovery: evidence showed tether permitted walking and no deliberate indifference as a matter of law |
| Medical Center liability under Monell for deferring to law enforcement on restraints | Plaintiff: hospital practice of deferring to officers caused unconstitutional shackling | Medical Center: medical staff routinely request removal/adjustment; treating physicians could and did influence restraint use | Affirmed for Medical Center: plaintiff failed to show the hospital’s practice exposed her to substantial risk or deliberate indifference |
| Claims re: breast pump, pregnancy nutrition, and equal protection based on national origin | Plaintiff: denial/refusal to provide breast pump and inadequate pregnancy diet; restraint policy disproportionately impacts noncitizen Hispanic women | Defendants: no municipal policy caused breast‑pump denial; diet met pregnancy supplementation; no evidence of discriminatory intent or disproportionate impact | Affirmed for defendants: summary judgment proper on breast pump and nutrition claims (no Monell theory/evidence); equal protection claim failed for lack of intent or comparative statistics |
Key Cases Cited
- Monell v. New York City Dep’t of Social Servs., 436 U.S. 658 (municipal liability requires causal municipal policy)
- Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train requires deliberate indifference)
- Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate indifference standard)
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs violates Eighth Amendment)
- Hope v. Pelzer, 536 U.S. 730 (obviousness of constitutional violation relevant to notice)
- Helling v. McKinney, 509 U.S. 25 (seriousness inquiry asks whether society tolerates the risk)
- Bell v. Wolfish, 441 U.S. 520 (deference to prison officials for institutional security)
- Chess v. Dovey, 790 F.3d 961 (9th Cir.) (medical needs vs. security conflicts—deference instruction guidance)
- Lopez-Valenzuela v. Arpaio, 770 F.3d 772 (9th Cir.) (context re: pretrial detention statute)
- Villegas v. Metro. Government, 709 F.3d 563 (6th Cir.) (shackling in labor can pose substantial risk and violate Eighth Amendment)
- Nelson v. Correctional Med. Servs., 583 F.3d 522 (8th Cir.) (shackling in late labor presents substantial risk)
- Lemire v. Cal. Dep’t of Corr. & Rehab., 726 F.3d 1062 (9th Cir.) (serious medical need and jury determination)