(PC) Morehouse v. K.C.S.O.
1:16-cv-00986
E.D. Cal.Sep 22, 2016Background
- Plaintiff Jody Morehouse, a pretrial detainee, sued Kern County Sheriff’s Office and Kern County Mental Health under 42 U.S.C. § 1983 for failure to provide prescribed psychiatric medications (klonopin and Remeron).
- Morehouse alleges he has bipolar and anxiety disorders and went without medications since incarceration, causing anxiety and depression.
- Complaint seeks injunctive relief and monetary damages; no individual defendants were named.
- Case is before the magistrate judge on screening under 28 U.S.C. §§ 1915A and 1915(e)(2) because plaintiff proceeds in forma pauperis.
- Court found the complaint failed to plead municipal liability or facts linking individuals to constitutional deprivations and dismissed the complaint with leave to amend.
- Plaintiff was given 30 days to file an amended complaint addressing deficiencies or the case will be dismissed with prejudice under § 1915(g).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability (Monell) | KCSO and County Mental Health policies or omissions caused deprivation by denying meds | No specific policy or deliberate-indifference facts tying county to violation | Dismissed: plaintiff failed to plead a policy/practice or deliberate indifference sufficient for municipal liability; leave to amend granted |
| Linkage to individual defendants | (No individuals named) Implicitly claims staff denied meds | No opportunity to respond; court requires specific allegations against individuals | Dismissed as pleaded; court instructed how to plead individual liability under § 1983 and granted leave to amend |
| Adequacy of medical care (pretrial detainee standard) | Denial of meds violated rights and caused harm | Court evaluates under Fourteenth Amendment framework; plaintiff must plead facts showing objectively unreasonable conduct causing harm | Dismissed: allegations conclusory and nonspecific (no requests, notice to staff, reasons, or resulting substantial risk); leave to amend granted |
| Pleading sufficiency / Leave to amend | Complaint states claim sufficiently | Complaint lacks factual detail and linkage; must meet Rule 8/Iqbal/Twombly plausibility standards | Complaint dismissed for failure to state a claim; plaintiff may amend within 30 days or face dismissal with prejudice |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards: legal conclusions insufficient)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires policy or custom causing constitutional violation)
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (objective standard for certain Fourteenth Amendment detainee claims)
- Castro v. County of Los Angeles, 797 F.3d 654 (9th Cir. 2015) (Monell and Fourteenth Amendment standards for detainees)
- Gibson v. County of Washoe, 290 F.3d 1175 (9th Cir. 2002) (municipal liability via omission and deliberate indifference)