Oxley v. Contra Costa County Sheriff Department
5:23-cv-00510
| N.D. Cal. | Jun 28, 2023Background
- Plaintiff, a pretrial detainee at West County Detention Facility, alleges deputies detained him on July 7, 2022, and placed handcuffs too tightly during transport from Rodeo to Martinez.
- Plaintiff repeatedly asked Deputies Daniel Husted, Samuel Jones, and Zachary Williams to loosen the handcuffs; his requests were ignored and the restraints caused swelling and later neurologic symptoms.
- Detective Gianopoulos Andreas observed Plaintiff’s injured hands, told Plaintiff someone would see him, but no medical care was provided that day; months later a neurologist diagnosed nerve damage and prescribed wrist splints and possible surgery.
- Plaintiff filed a §1983 suit seeking damages against Deputies Jones, Husted, Williams, Detective Andreas, and (erroneously listed) Contra Costa County Sheriff entities.
- The court found the handcuff allegations sufficient to state a Fourth Amendment excessive-force claim against Jones, Husted, and Williams, and found the medical-screening/medical-care allegation sufficient to state a due-process claim against Andreas; it ordered service on those four individuals and terminated the county sheriff entities.
- The court set procedural deadlines: waiver of service to be sought, defendants to file any dispositive motion (e.g., summary judgment) within 91 days, and briefing deadlines (28 days to oppose, 14 days to reply), with Rand warnings required if summary judgment is filed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (tight handcuffs) | Oxley alleges cuffs were overly tight, caused immediate injury and lasting nerve damage | (No answer yet) likely deny force was excessive or dispute causation | Court found allegations sufficient to state a Fourth Amendment excessive-force claim against Jones, Husted, and Williams |
| Denial/delay of medical care | Oxley alleges he requested care, Andreas saw swelling and promised care but none was provided that day, leading to injury | (No answer yet) likely deny deliberate indifference or contend screening/triage was adequate | Court found allegations sufficient to state a due-process/medical-screening claim against Andreas |
| County Sheriff entities as defendants | Docket included Contra Costa County Sheriff Department/Contra Costa County Sheriff | Those entities are not listed in plaintiff’s party list and no specific allegations were pleaded against them | Court ordered termination of “Contra Costa County Sheriff Department” and “Contra Costa County Sheriff” from the case |
| Service and dispositive-motion procedure | Oxley seeks relief; case to proceed against named individuals | (Procedural) Defendants must waive service per Rule 4 or bear costs; may move for summary judgment | Court directed clerk to mail waiver forms, warned defendants re: costs for refusing waiver, set 91-day deadline for dispositive motions and standard briefing schedule with Rand warnings |
Key Cases Cited
- Balistreri v. Pacifica Police Dep't, 901 F.2d 696 (9th Cir. 1988) (pro se pleadings must be liberally construed)
- West v. Atkins, 487 U.S. 42 (1988) (elements of a §1983 claim require state action and constitutional violation)
- LaLonde v. County of Riverside, 204 F.3d 947 (9th Cir. 2000) (claims based on tight handcuffs can constitute Fourth Amendment excessive force)
- Gordon v. Orange County, 6 F.4th 961 (9th Cir. 2021) (pretrial detainee due-process right includes adequate medical screening and care)
- Rand v. Rowland, 154 F.3d 952 (9th Cir. 1998) (en banc) (procedural warnings required when a pro se prisoner faces summary-judgment motion)
- Woods v. Carey, 684 F.3d 934 (9th Cir. 2012) (discusses application of Rand warnings in summary-judgment context)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary-judgment standard requiring nonmoving party to show triable issues of material fact)
- Ghazali v. Moran, 46 F.3d 52 (9th Cir. 1995) (failure to oppose a motion may be deemed consent to its granting)
- Brydges v. Lewis, 18 F.3d 651 (9th Cir. 1994) (same)
