William King v. County of Los Angeles
885 F.3d 548
9th Cir.2018Background
- William King was civilly detained under California’s SVPA in Los Angeles County jails from Nov. 2005 to Aug. 2013 while awaiting commitment adjudication; he spent ~1.25 years in the jail SVP unit and ~6.5 years in Administrative Segregation (AdSeg).
- SVP detainees wore distinctive red uniforms, had severely restricted movement, limited property/phone/contact visitation, and were treated similarly to criminal detainees in jail; by contrast, Coalinga State Hospital offered dorm living, treatment, family visits, recreation, and other patient-oriented privileges.
- While in AdSeg among criminal detainees, King was repeatedly threatened and in Nov. 2006 was attacked and slashed by another inmate; he repeatedly requested return to the SVP unit but was denied.
- King sued the County and Sheriff Baca under 42 U.S.C. § 1983, alleging substantive due process violations from punitive conditions imposed on a civil detainee; he sought damages and injunctive relief.
- The district court granted summary judgment to defendants (County and Sheriff Baca), finding no admissible Coalinga comparison evidence and that King’s AdSeg placement was justified by violent tendencies; the Ninth Circuit reversed as to County and Sheriff Baca in his official capacity, affirmed as to Baca individually, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SVP-unit jail conditions and AdSeg confinement constituted "punishment" in violation of substantive due process for civil detainees | King: confinement conditions were similar to or more restrictive than criminal detainees’ and more restrictive than post-commitment conditions (Coalinga), so presumptively punitive | County/Baca: conditions served legitimate, non-punitive interests (security, facility management); King’s violent disciplinary history justified AdSeg | Court: Both Jones presumptions triggered for SVP unit and AdSeg; presumptions shift burden to defendants to identify specific non-punitive interests and show restrictions not excessive; remand to evaluate rebuttal evidence |
| Whether defendants met burden to rebut Jones presumptions by showing legitimate, non-punitive interests and proportionality | King: defendants did not justify extended, harsh confinement or show less-restrictive alternatives; long duration matters | Defendants: cited security, detainee management, and King’s alleged violent tendencies/K-10 classification | Court: district court erred to grant summary judgment; factual disputes (e.g., improper K-10 classification, duration) require remand for fact-specific analysis |
| Liability of County and Sheriff Baca (official capacity) under Monell for policies causing unconstitutional conditions | King: Unit Orders and County policies governed SVP unit and AdSeg and caused the conditions | County/Baca: challenged causation and justification; argued policies lawful | Court: Reversed summary judgment — County and Sheriff Baca (official) may be liable because Unit Orders guided King’s treatment and could have caused violations |
| Liability of Sheriff Baca in his individual capacity as supervisor | King: Baca liable for supervisory failure/setting in motion policies | Baca: no personal involvement or causal connection to King’s placement or daily operations | Court: Affirmed summary judgment for Baca individually — record lacks evidence of personal involvement or requisite causal connection |
Key Cases Cited
- Jones v. Blanas, 393 F.3d 918 (9th Cir. 2004) (establishes presumptions that civil SVP detainees’ jail conditions are presumptively punitive if like criminal conditions or more restrictive than post-commitment conditions)
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (civil detainees cannot be subjected to conditions amounting to punishment)
- Youngberg v. Romeo, 457 U.S. 307 (U.S. 1982) (civilly committed persons entitled to more considerate treatment than criminal detainees)
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (U.S. 1978) (municipal liability under § 1983 for unconstitutional policies or customs)
- Starr v. Baca, 652 F.3d 1202 (9th Cir. 2011) (standards for supervisor liability under § 1983)
- Gilbertson v. Albright, 381 F.3d 965 (9th Cir. 2004) (Younger abstention and federal-court intervention principles)
- Walker v. Sumner, 917 F.2d 382 (9th Cir. 1990) (defendant must identify specific penological interests and relate policies reasonably to those interests)