Yellin v. Quiroz, Jr.
1:24-cv-01216
| E.D. Va. | Jun 30, 2025Background
- Plaintiff Laura Yellin, a deaf woman, was arrested and detained in Arlington County Detention Facility (ACDF) after violating a protective order.
- Yellin relies on cochlear implants for hearing but lacked charged batteries during her detention, rendering her unable to communicate orally.
- She requested but was denied an American Sign Language (ASL) interpreter by sheriff’s staff during intake, hindering her ability to communicate her medical needs or understand facility procedures.
- Plaintiff, who suffered postpartum psychosis and preeclampsia, alleges she was held in solitary confinement for 23 hours a day for nearly five weeks.
- Yellin asserted Section 1983 claims for cruel and unusual punishment and failure to train, as well as ADA/Rehabilitation Act claims. This opinion addresses the Sheriff Defendants' motion to dismiss her Section 1983 claims (Count I).
- At this stage (motion to dismiss), the court accepted all non-conclusory factual allegations in the complaint as true.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of § 1983 cruel punishment | Defendants personally participated; solitary & denial of needs violated Eighth Amendment | Plaintiff failed to allege individual roles in solitary placement | Sufficient factual allegations to proceed |
| § 1983 failure to train (Sheriff Quiroz) | Quiroz failed to train staff on care for deaf inmates—a pattern & obvious duty | Reference to prior consent decree is too conclusory, causation lacking | Allegations adequate to plead notice & causation |
| Qualified immunity at motion to dismiss | Immunity is premature at pleading stage, factual issues exist | Entitled to qualified immunity, role in misconduct not pled specifically | Deferred—denied without prejudice pending discovery |
| Official/individual capacity distinction | Claims are against Quiroz personally under § 1983 | Argued sovereign immunity for official capacity | Only individual capacity at issue, so rejected |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (complaints must allege plausible claims, not conclusions)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard requires plausibility)
- Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate indifference standard)
- Wilcox v. Brown, 877 F.3d 161 (personal involvement required for Section 1983 liability)
- Langford v. Joyner, 62 F.4th 122 (notice pleading suffices; need sufficient facts per defendant)
- Porter v. Clarke, 923 F.3d 348 (extended solitary confinement can violate Eighth Amendment)
- Thorpe v. Clarke, 37 F.4th 926 (risk of psychological harm in solitary relevant for Eighth Amendment)