Shane Horton v. City of Santa Maria
915 F.3d 592
| 9th Cir. | 2019Background
- Shane Horton, an 18-year-old pretrial detainee with recent drug use and a prior 5150 hospitalization, was arrested for vandalism and placed in a temporary holding cell.
- Horton was cooperative and repeatedly denied current medical problems when asked by officers.
- Officer Brice interviewed Horton and then spoke by phone for ~10–15 minutes with Horton’s mother, who (in the light most favorable to Horton) told Brice that Horton had been suicidal two weeks earlier and pleaded that the officers watch him.
- Brice did not immediately return to the cell; roughly 27 minutes after leaving Horton unattended, Brice found Horton hanging from his belt and suffering severe, permanent brain damage from prolonged anoxia.
- Horton sued under 42 U.S.C. § 1983 (Fourteenth Amendment deliberate indifference/failure-to-protect) against Brice and municipal defendants (Monell), and under California Government Code § 845.6 for failure to summon immediate medical care; the district court denied summary judgment to Brice on § 1983 and to the municipality on Monell and denied summary judgment to Brice and the city on § 845.6.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualified immunity for Officer Brice on § 1983 Fourteenth Amendment deliberate-indifference/failure-to-protect claim | Horton: Brice knew enough (mother’s warnings, prior suicidal history, recent violent/drug behavior) that failing to check immediately was deliberately indifferent to an imminent suicide risk. | Brice: No clearly established law required an officer in these facts to perceive an imminent substantial risk and immediately return; summary denial of qualified immunity improper. | Reversed: Brice entitled to qualified immunity because existing precedent at the time did not clearly establish that a reasonable officer must have known his failure to check immediately was unlawful. |
| Appealability/jurisdiction over denial of summary judgment to municipal defendants on Monell claim | Horton: Denial of municipality’s summary judgment should be reviewable alongside Brice’s qualified-immunity appeal. | City: Municipal summary-judgment denial is not immediately appealable; pendent review only if claims are inextricably intertwined. | No jurisdiction: Denial of Monell summary judgment not reviewable here because resolution of Brice’s qualified immunity does not necessarily resolve municipal liability. Case remanded for district court to consider Monell under updated law. |
| California Government Code § 845.6 claim (state-law immunity/failure to summon medical care) | Horton: Brice and city had reason to know Horton required immediate medical/mental health care; failing to summon timely care caused injury. | Brice/City: § 845.6 immunity bars suit absent knowledge of immediate need or the claim really alleges failure to diagnose/provide care (an excluded category). | Affirmed: Denial of summary judgment on § 845.6 was proper — genuine factual dispute whether Brice had reason to know of an immediate need and failed to summon timely care; this is for a jury. |
| Applicable constitutional standard for future Fourteenth Amendment claims by detainees | Horton: (implicit) deliberate indifference standard should govern and Brice’s conduct violate it. | Defendants: point to prior mixed law; appellate court clarifies applicable standard. | Court notes doctrinal change post-incident: Castro/Gordon adopt an objective standard for pretrial detainees (no subjective intent inquiry) to guide future cases, but qualifies that change does not affect the qualified-immunity analysis here. |
Key Cases Cited
- Saucier v. Katz, 533 U.S. 194 (framework for qualified immunity/context-specific inquiry)
- Pearson v. Callahan, 555 U.S. 223 (discretion to decide qualified immunity prongs)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard elements)
- Conn v. City of Reno, 591 F.3d 1081 (officers observed detainee threaten/attempt suicide—duty to report/act)
- Clouthier v. County of Contra Costa, 591 F.3d 1232 (mental-health specialist removed suicide prevention measures; no qualified immunity)
- Estate of Ford v. Ramirez-Palmer, 301 F.3d 1043 (focus qualified-immunity inquiry on objective aspects of deliberate indifference)
- Castro v. County of Los Angeles, 833 F.3d 1060 (en banc: objective standard for pretrial detainee failure-to-protect claims)
- Gordon v. County of Orange, 888 F.3d 1118 (applies Castro objective standard to pretrial detainee medical-care claims)
- Monell v. Department of Social Servs., 436 U.S. 658 (municipal liability under § 1983)
- Mitchell v. Forsyth, 472 U.S. 511 (denial of qualified immunity is immediately appealable)
- Jett v. Penner, 439 F.3d 1091 (§ 845.6: triable issues about "immediate medical care" can exist; immediacy not strictly emergency-only)