Schmidt v. County of San Diego
3:23-cv-00899
S.D. Cal.Apr 14, 2025Background
- The plaintiffs' father, Gilbert Gil, died in custody at the Vista Detention Facility, allegedly due to defendants' failure to provide adequate medical care for his severe hypertension.
- Plaintiffs initially filed suit against the County of San Diego, a nurse, and unnamed (Doe) defendants, asserting several federal and state claims, including violations of Mr. Gil’s constitutional rights under 42 U.S.C. § 1983, negligence, and wrongful death.
- The Court previously dismissed certain claims (e.g., Bane Act and punitive damages against the County) while allowing others to proceed, finding the pleadings regarding Doe defendants sufficient.
- Plaintiffs moved to amend their complaint a third time, mainly to substitute the identities of Doe defendants and add supporting facts learned in discovery.
- Defendants opposed, arguing the continued use of Doe defendants and that § 1983 claims against new individuals are time-barred; they did not allege bad faith or prejudice from the amendment.
- The Court considered whether the amendment should be allowed under Federal Rule of Civil Procedure 15(a).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether leave to file a Third Amended Complaint should be granted | Justice requires allowing amendment to substitute Doe defendants and add new facts | Amendment adding Doe defendants is improper, violates prior court guidance, and is futile | Leave to amend granted; Doe defendants’ allegations are sufficient |
| Sufficiency of pleadings against Doe defendants | Allegations adequately identify Doe defendants' conduct and responsibility | Claims against Doe defendants are too vague and use improper group pleading | Court finds pleadings sufficient, consistent with prior order |
| Whether adding §1983 claims against newly named Doe defendants is time-barred | Claims arise from same core facts as original complaint; relation-back doctrine applies | Claims are time-barred due to insufficient description of Doe defendants | Court finds claims are not time-barred; relation-back applies |
| Potential prejudice or bad faith in amendment | No prejudice or bad faith; amendments necessary based on discovery | Did not argue prejudice or bad faith | No evidence of prejudice or bad faith; amendment appropriate |
Key Cases Cited
- Pisciotta v. Teledyne Indus., Inc., 91 F.3d 1326 (9th Cir. 1996) (district court has discretion to grant leave to amend)
- DCD Programs, Ltd. v. Leighton, 833 F.2d 183 (9th Cir. 1987) (leave to amend should be granted with 'extreme liberality')
- Johnson v. Buckley, 356 F.3d 1067 (9th Cir. 2004) (five-factor test for leave to amend)
- Jackson v. Bank of Hawaii, 902 F.2d 1385 (9th Cir. 1990) (leave to amend is not automatic)
- Martell v. Trilogy Ltd., 872 F.2d 322 (9th Cir. 1989) (relation-back doctrine for amendments involving Doe defendants)