William Curry, Jr. v. Elena Lopez
683 F. App'x 637
| 9th Cir. | 2017Background
- Civil detainee William Curry, Jr. sued under 42 U.S.C. § 1983 challenging conditions and treatment during his civil confinement, including placement in an intensive management unit (IMU).
- District court granted summary judgment for defendants on all claims; Curry appealed pro se to the Ninth Circuit.
- Curry asserted multiple constitutional claims: due process (conditions/punishment), equal protection, denial of access to courts, failure-to-protect, and retaliation.
- The Ninth Circuit reviewed the district court’s grant of summary judgment de novo and permitted affirmance on any record-supported basis.
- The panel concluded Curry failed to raise genuine disputes of material fact on each claim and affirmed the district court’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process — IMU placement | IMU placement amounted to punishment and violated detainee due process rights | Placement was reasonably related to legitimate governmental objectives, not punitive | Affirmed — no evidence of intent to punish; placement rationally related to legitimate objectives (Bell standard) |
| Equal protection | He was treated differently than similarly situated persons or discriminated as a protected-class member | Treatment was not intentional discrimination or irrational differential treatment | Affirmed — no genuine issue that defendants intentionally treated him differently without rational basis or due to protected status |
| Access to courts | Denial of materials/conditions impeded non-frivolous legal claims | No showing defendants caused actual injury to a non-frivolous claim | Affirmed — plaintiff failed to show actual injury required for access-to-courts claim (Lewis standard) |
| Failure-to-protect & Retaliation | Officials failed to protect him from serious harm and took adverse actions in retaliation for protected conduct | Defendants took reasonable measures and did not act with retaliatory motive | Affirmed — no genuine dispute that defendants omitted reasonable measures or acted for retaliatory reasons |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detention restrictions are punitive only if intended as punishment; otherwise valid if reasonably related to legitimate objectives)
- Vill. of Willowbrook v. Olech, 528 U.S. 562 (2000) (elements of equal protection "class of one" claim)
- Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claim requires actual injury to non-frivolous claim)
- Castro v. County of Los Angeles, 833 F.3d 1060 (9th Cir. 2016) (en banc) (Fourteenth Amendment failure-to-protect standards for pretrial detainees)
- Rhodes v. Robinson, 408 F.3d 559 (9th Cir. 2005) (elements of retaliation claim in prison context)
- Riggs v. Prober & Raphael, 681 F.3d 1097 (9th Cir. 2012) (standard of de novo review on appeal)
- Enlow v. Salem-Keizer Yellow Cab Co., 389 F.3d 802 (9th Cir. 2004) (appellate court may affirm on any basis supported by the record)
- Barren v. Harrington, 152 F.3d 1193 (9th Cir. 1998) (procedural guidance on § 1983 equal protection elements)
- Padgett v. Wright, 587 F.3d 983 (9th Cir. 2009) (issues not raised in opening brief or raised first on appeal are not considered)