Starr v. Baca
2011 U.S. App. LEXIS 15283
| 9th Cir. | 2011Background
- Starr, a former Los Angeles County Jail inmate, sues Sheriff Baca under 42 U.S.C. §1983 for unconstitutional conditions of confinement.
- Attack incident occurred Jan 27, 2006; inmates entered Starr’s cell after a deputy opened the door; Starr stabbed 23 times and kicked by deputies while others watched; Starr sought medical attention but faced delays.
- District court dismissed Starr’s supervisory liability claim against Sheriff Baca for deliberate indifference under Rule 12(b)(6) for lack of causal link and policy connection.
- Court reviews de novo; Iqbal prompted supplemental briefing; majority holds Starr adequately pleads supervisory liability for deliberate indifference.
- Court reverses and remands, holding Iqbal did not preclude supervisory liability in this context and Starr’s Rule 8(a) pleading is sufficient to state such a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Iqbal eliminates supervisory liability for deliberate indifference | Starr asserts supervisory liability survives Iqbal. | Baca argues Iqbal bars such supervisory claims. | Iqbal does not bar supervisory liability here. |
| Whether Starr states a sufficient causal connection | Starr contends knowledge and acquiescence by Baca show causation. | Baca contends no direct participation or policy link. | Sufficient causal connection shown; acquiescence supports liability. |
| Whether Starr's Rule 8(a) pleading is adequate | Complaint provides detailed incidents and notices. | Complaint relies on conclusions; fails to plead facts. | Rule 8(a) pleading is adequate; allegations plausibly state a claim. |
| Whether Starr may pursue individual liability of Sheriff vs. official-capacity claims | Starr should be able to hold Baca individually liable. | Individual liability requires personal involvement or causation; insufficient here. | Majority allows a plausible individual supervisory liability claim; remand for proceedings. |
Key Cases Cited
- Larez v. City of Los Angeles, 946 F.2d 630 (9th Cir. 1991) (supervisor need not be on scene; can be liable for training/supervision or acquiescence)
- Redman v. County of San Diego, 942 F.2d 1446 (9th Cir. 1991) (causal connection via knowledge and acquiescence may establish liability)
- Dubner v. City & Cnty. of San Francisco, 266 F.3d 959 (9th Cir. 2001) (supervisor liable for knowingly refusing to terminate harmful acts by others)
- Watkins v. City of Oakland, 145 F.3d 1087 (9th Cir. 1998) (supervisor liability includes control/monitoring of subordinates)
- Erickson v. Pardus, 551 U.S. 89 (2007) (Court rejected dismissals for failure to plead under Rule 8(a) in pro se context)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (no heightened pleading standard for discrimination claims under Rule 8(a))