Starr v. Baca
633 F.3d 1191
9th Cir.2011Background
- Starr, a §1983 plaintiff, sues Sheriff Baca in his individual capacity for deliberate indifference under the Eighth and Fourteenth Amendments.
- The Jan. 27, 2006 incident at Los Angeles County Jail involved inmates stabbing Starr and his cellmate after deputies opened Starr’s cell door to let the attackers in.
- A deputy yelled a racial slur and assaulted Starr; other deputies stood by and Starr could not obtain timely medical treatment.
- The district court dismissed Starr’s supervisory liability claim under Rule 12(b)(6) for lack of a causal connection and personal involvement, entering final judgment under Rule 54(b).
- The appellate court held Iqbal did not eliminate supervisory liability in deliberate-indifference conditions cases, reinstated Starr’s claim, and remanded for further proceedings.
- Starr’s allegations focus on Sheriff Baca’s knowledge of systemic jail deficiencies and his acquiescence or inaction allowing unconstitutional conditions to continue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Iqbal bars supervisory liability claims for deliberate indifference. | Starr argues Iqbal does not eliminate supervisory liability in these cases. | Baca contends Iqbal eliminates supervisory liability for deliberate indifference. | Iqbal does not bar supervisory liability under deliberate indifference |
| Whether Starr adequately pled a causal connection for supervisor liability. | Starr alleges Baca knew of subordinates’ misconduct and acquiesced. | Baca contends no direct participation or moving-policy link is pled. | Sufficient causal connection shown by knowledge and acquiescence (not vicarious liability) |
| Whether Starr’s complaint satisfies Rule 8(a) post-Iqbal. | Starr’s detailed, non-conclusory allegations give notice and plausibility. | Dissent contends the pleading is conclusory and insufficient under Iqbal. | Complaint satisfies Rule 8(a); allegations are detailed and plausible |
Key Cases Cited
- Larez v. City of Los Angeles, 946 F.2d 629 (9th Cir.1991) (supervisor liability can proceed without direct on-scene participation)
- Redman v. County of San Diego, 942 F.2d 1435 (9th Cir.1991) (causal connection through knowledge or acquiescence may establish supervisor liability)
- Dubner v. City & Cnty. of San Francisco, 266 F.3d 959 (9th Cir.2001) (supervisor liability can arise from knowingly failing to terminate a series of acts by others)
- Watkins v. City of Oakland, 145 F.3d 1087 (9th Cir.1998) (supervisor liability includes training, supervision, control, or acquiescence)
- Iqbal v. Ashcroft, 129 S. Ct. 1937 (U.S. 2009) (post-Iqbal pleading standard for individual liability; not all allegations survive)
- Twombly v. Bell Atlantic Corp., 550 U.S. 544 (2007) (pleading must be plausible; bare allegations insufficient)
- Erickson v. Pardus, 551 U.S. 89 (2007) (courts should not dismiss where Rule 8(a) pleading shows notice and plausibility)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (Rule 8(a) notice pleading remains; no heightened standard for discrimination claims)
- Pembaur v. City of Cincinnati, 475 U.S. 469 (1986) (official policy or custom can render a supervisor liable in official capacity)