University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Rodriguez v. County of Los Angeles JC-CA-0111
Docket / Court 2:10-cv-06342-CBM-AJW ( C.D. Cal. )
State/Territory California
Case Type(s) Jail Conditions
Special Collection California's Prisoners' Rights Bar article
Attorney Organization Kaye, McLane, Bednarski & Litt
Case Summary
On August 20, 2010, five inmates in the Los Angeles County Men's Central Jail filed this lawsuit in the U.S. District Court for the Central District of California. Proceeding under 42 U.S.C. § 1983 against deputy sheriffs, ... read more >
On August 20, 2010, five inmates in the Los Angeles County Men's Central Jail filed this lawsuit in the U.S. District Court for the Central District of California. Proceeding under 42 U.S.C. § 1983 against deputy sheriffs, the plaintiffs, represented by private counsel, asked the court for damages, claiming violations of the Eighth and Fourteenth Amendments to the US Constitution. Specifically, the inmates claimed that the deputies systematically beat them during a cell extraction after the inmates protested conditions at the Jail by refusing to leave their cells.

On February 25, 2013, Judge Consuelo B. Marshall denied plaintiffs' motion to strike the defendants' answer and enter judgment, but Judge Marshall did grant the plaintiffs' alternative motion to impose other lesser sanctions for spoliation of evidence.

On July 12, 2013, Judge Marshall denied the defendants' motions for summary judgment but granted a defendant's motion for joinder and plaintiffs' motion in limine to admit the Citizens' Commission on Jail Violence Report. The defendants appealed this decision to the Ninth Circuit. The plaintiffs moved that this appeal was frivolous. The Ninth Circuit denied the defendants' motion to stay the district court proceedings pending the appeal. As such, the district court proceedings continued and the Ninth Circuit never ruled on this appeal.

After a five week trial, on February 5, 2014, the jury returned a unanimous verdict of civil rights violations triggering $710,000 in damages and $240,000 in punitive damages. In addition, the district court awarded $5.4 million in attorney fees based on the difficulty of the litigation and the challenge of representing convicted inmates against law enforcement in a jail conflict. After this judgment, the defendants moved for judgment as a matter of law, to vacate the judgment and for a new trial, to vacate punitive damages, and/or for a new trial. The defendants also appealed the judgment to the Ninth Circuit Court of Appeals. In 2014 and 2015, the defendants filed a total of three amended appeals to the Ninth Circuit.

On May 29, 2014, Judge Marshall denied all defendants' motions (1) for judgment as matter of law; (2) to vacate judgment and for a new trial after resolution of interlocutory qualified immunity appeals; (3) to vacate punitive damages; and (4) for a new trial. 2014 WL 8396787 (C.D. Cal. May 29, 2014).

On December 29, 2014, Judge Marshall issued an order and opinion regarding attorney's fees. Most importantly, Judge Marshall held that (1) California's Bane Act's attorney's fees provision did not conflict with the Prison Litigation Reform Act; (2) the majority of services rendered in opposition to summary judgment would be as §1983 only time (and therefore receiving lower reimbursement rates), rather than under the Bane Act; and (3) inmates were entitled to recover fully compensatory attorney fees. 2014 WL 8390755 (C.D. Cal. Dec. 29, 2014).

The appeal of the trial judgment is still pending in the Ninth Circuit. In the district court, the plaintiff moved to retax costs on May 15, 2015, and the district court has not ruled on this motion. The Ninth Circuit is waiting for the district court to rule before it issues an order or opinions.

Jessica Kincaid - 10/30/2015


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Issues and Causes of Action
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Issues
Affected Gender
Male
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Defendant-type
Corrections
General
Assault/abuse by staff
Excessive force
Failure to discipline
Failure to supervise
Failure to train
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action State law
42 U.S.C. § 1983
Defendant(s) Los Angeles County
Plaintiff Description Five inmates at the Los Angeles County Men's Central Jail
Indexed Lawyer Organizations Kaye, McLane, Bednarski & Litt
Class action status sought No
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Attorneys fees
Damages
Source of Relief Litigation
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Yes
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
2:10-cv-06342 (C.D. Cal.) 06/26/2015
JC-CA-0111-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Damages for Violations of Federal Civil Rights (Eighth and Fourteenth Amendment) 08/25/2010
JC-CA-0111-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Second Amended Complaint for Damages for Violations of Federal Civil Rights (Eighth and Fourteenth Amendment) 09/26/2011
JC-CA-0111-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Denying Plaintiff's Motion to Strike Defendants' Answer and Enter Judgment but Granting Plaintiffs' Alternative to Impose Other Lesser Sanctions for Spoliation of Evidence 02/25/2013 (C.D. Cal.)
JC-CA-0111-0003.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Denying Motions for Summary Judgment, Granting Motion for Joinder, and Granting Motion in Limine 07/12/2013 (C.D. Cal.)
JC-CA-0111-0004.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Plaintiffs' Memorandum of Contentions of Fact and Law 07/29/2013
JC-CA-0111-0005.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Defendant Hernan Delgado's Memorandum of Contentions of Fact and Law 07/29/2013
JC-CA-0111-0006.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judgment 02/05/2014 (C.D. Cal.)
JC-CA-0111-0007.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Denying Defendants' Motions (1) for Judgment as a Matter of Law; (2) Motion to Vacate Judgment as to Moving Defendant as and for a New Trial for These Defendants After Resolution of Interlocutory Qualified Immunity Appeals; (3) to Vacate... 05/29/2014 (2014 WL 8396787) (C.D. Cal.)
JC-CA-0111-0008.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Defendants' Third Amended Notice of Appeal (Ninth Circuit Docket No. 14-55374) as to Docket No. 747 06/26/2014
JC-CA-0111-0009.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Defendant Delgado's Amended Notice of Appeal (Ninth Circuit Docket No. 14-55374) as to Docket No. 747 06/26/2015
JC-CA-0111-0010.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Marshall, Consuelo Bland (C.D. Cal.)
JC-CA-0111-0003 | JC-CA-0111-0004 | JC-CA-0111-0007 | JC-CA-0111-0008 | JC-CA-0111-9000
Wistrich, Andrew J. (C.D. Cal.) [Magistrate]
JC-CA-0111-9000
Monitors/Masters None on record
Plaintiff's Lawyers Kaye, Ronald O. (California)
JC-CA-0111-0005 | JC-CA-0111-9000
LaHue, Kevin J. (California)
JC-CA-0111-9000
Litt, Barrett S. (California)
JC-CA-0111-9000
McLane, David S. (California)
JC-CA-0111-9000
Muller, James S. (California)
JC-CA-0111-0001 | JC-CA-0111-0002 | JC-CA-0111-0005 | JC-CA-0111-9000
Weisberg, Caitlin S. (California)
JC-CA-0111-9000
Defendant's Lawyers Allen, Matthew Philip (California)
JC-CA-0111-9000
Beach, Paul B (California)
JC-CA-0111-9000
Cha, Daniel S. (California)
JC-CA-0111-9000
Choi, Jin S (California)
JC-CA-0111-0009 | JC-CA-0111-9000
Gonzales, Dennis Michael (California)
JC-CA-0111-9000
Lawrence, David D. (California)
JC-CA-0111-9000
Morris, George E. Jr. (California)
JC-CA-0111-9000
Nishimura, Gilbert M. (California)
JC-CA-0111-0006 | JC-CA-0111-9000
Pongracz, Andrew Charles (California)
JC-CA-0111-0010 | JC-CA-0111-9000
Rathbun, J. Edwin (California)
JC-CA-0111-0006 | JC-CA-0111-9000
Other Lawyers None on record

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