Rukhsana Chaudhry v. City of Los Angeles
751 F.3d 1096
| 9th Cir. | 2014Background
- On March 25, 2008 LAPD Officer Joseph Cruz shot and killed Mohammad Usman Chaudhry; the Los Angeles County Coroner took custody of the body but did not notify next of kin for 21 days, which prevented a timely religious burial and resulted in decomposition.
- Plaintiffs: the Estate of Usman, his parents (the Chaudhrys), siblings (Usma and Umar), and three organizations; Defendants: City of Los Angeles, Officer Cruz, County, and Coroner officials.
- At trial the jury found Cruz used excessive force causing Usman’s death and awarded $1,000,000 to the Estate (pain and suffering under § 1983) and $700,000 to the parents (state wrongful death claim).
- The district court granted judgment as a matter of law for the $1,000,000 award, holding California’s survival statute (Cal. Civ. Proc. Code § 377.34) bars pre-death pain-and-suffering recovery and that rule applies in § 1983 cases; it also dismissed several state and federal claims pretrial and cut attorneys’ fees heavily.
- The Ninth Circuit reversed in part and affirmed in part: it held California’s bar on pre-death pain-and-suffering does not apply to § 1983 claims when federal-law violations cause death; reinstated certain state and federal claims (including Cal. Civ. Code § 52.1 and parents’ substantive due process claim); reversed County summary judgment on coroner negligence; affirmed dismissal of some sibling claims; and vacated the fee award for reconsideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Cal. Civ. Proc. Code § 377.34 (no pre-death pain-and-suffering in survival actions) applies to § 1983 claims when federal violation caused death | Estate: § 377.34 is inconsistent with § 1983’s deterrence and compensation goals where the federal violation caused death, so pain-and-suffering damages are available | City: State rule governs damages in federal § 1983 suits under § 1988 unless inconsistent; § 377.34 is consistent | Reversed district court: § 377.34 does not apply to § 1983 claims where federal-law violation caused death; remand for possible remittitur review of the $1,000,000 award |
| Whether Estate’s Cal. Civ. Code § 52.1 claim should have been dismissed under Rule 12(b)(6) | Estate: A § 1983 excessive-force verdict supports a § 52.1 claim (no discriminatory intent required) | City: § 52.1 requires discriminatory intent and is duplicative of § 1983 | Reversed dismissal: § 52.1 claim may proceed; remedy differences (e.g., fee multipliers) justify separate claim |
| Whether parents (the Chaudhrys) stated a Fourteenth Amendment substantive due process claim for loss of companionship of an adult child | Chaudhrys: parents have a liberty interest in adult-child companionship and § 1983 remedy for unjustified killing | Cruz: parents lack a legal interest in an adult child once majority is reached; claim duplicative of state wrongful death | Reversed dismissal: Ninth Circuit recognizes parents’ liberty interest in adult-child companionship; reinstated claim (merits to be resolved) |
| Whether County/Coroner were entitled to summary judgment on negligence for delayed notification under Cal. Gov’t Code § 27471(a) | Chaudhrys: Coroner had mandatory statutory duty to make reasonable attempt to locate family; evidence created triable issue that duty was breached (investigator “overlooked” parents’ address) | County: either no mandatory duty or conduct was reasonable as a matter of law; Guzman and other authorities limit such duties | Reversed summary judgment: Davila controls that § 27471(a) imposes mandatory duty; genuine dispute of reasonableness for jury |
| Whether siblings (Usma and Umar) had standing and viable claims (IIED, substantive due process, negligence) for delayed notice | Siblings: suffered emotional injury from delayed notice and are entitled to damages for negligence | Defendants: siblings lacked a legally protected interest in disposition/notice and thus lacked Article III standing; IIED and substantive due process fail on merits | Mixed: Ninth Circuit held siblings have Article III standing; affirmed summary judgment dismissing IIED and substantive due process claims, but reversed as to negligence claim against County pending clarification of coroner’s duty scope |
| Whether district court’s attorneys’ fees award was proper | Plaintiffs: prevailing on § 1983 and § 52.1 claims justified lodestar plus possible California multiplier; submitted affidavits for prevailing market rates and hours | City: challenged rates/hours and degree of success; cross-appealed fee award | Vacated fee award: district court erred in blended-rate decision, excessive hour reductions without adequate explanation, and denying § 52.1 (so multiplier eligibility); remand for recalculation and fee-factor consideration |
Key Cases Cited
- Robertson v. Wegmann, 436 U.S. 584 (superseding statute may apply to § 1983 damages depending on consistency with § 1983 policies)
- Monell v. Dept. of Social Services, 436 U.S. 658 (municipal liability under § 1983)
- Monroe v. Pape, 365 U.S. 167 (§ 1983 remedy policy background)
- Bell v. City of Milwaukee, 746 F.2d 1205 (7th Cir.) (state survival limits inconsistent with § 1983 where federal violation caused death)
- Berry v. City of Muskogee, 900 F.2d 1489 (10th Cir.) (same conclusion for prison-death context)
- McFadden v. Sanchez, 710 F.2d 907 (2d Cir.) (state survival restrictions do not apply to § 1983 claims causing death)
- Porter v. Osborn, 546 F.3d 1131 (9th Cir.) (parents’ liberty interest in companionship of adult children)
- Hensley v. Eckerhart, 461 U.S. 424 (lodestar method and reasonableness standard for fee awards)
- Camacho v. Bridgeport Fin., Inc., 523 F.3d 973 (9th Cir.) (standards for proving prevailing market hourly rates and fee calculation)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requirements)
- Lexmark Int’l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377 (distinguishing standing from merits in certain contexts)