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Case Name Bock v. County of Sutter JC-CA-0120
Docket / Court 2:11-CV-00536-MCE ( E.D. Cal. )
State/Territory California
Case Type(s) Jail Conditions
Special Collection California's Prisoners' Rights Bar article
Attorney Organization Rosen, Bien, Galvan & Grunfeld
Case Summary
On February 24, 2011, the estate of a mentally ill inmate who committed suicide in the Sutter County Jail filed a lawsuit in the U.S. District Court for the Eastern District of California. The plaintiffs filed the lawsuit against Sutter County, the California Department of Mental Health, the county ... read more >
On February 24, 2011, the estate of a mentally ill inmate who committed suicide in the Sutter County Jail filed a lawsuit in the U.S. District Court for the Eastern District of California. The plaintiffs filed the lawsuit against Sutter County, the California Department of Mental Health, the county sheriff, and other mental health providers charged with his care. The plaintiffs, represented by private counsel, asked the court for compensatory and punitive damages alleging violations of the Eighth Amendment, the Fourteenth Amendment, Title II of the ADA, Section 504 of the Rehabilitation Act, and state law. The plaintiffs also allege medical malpractice, negligence, negligent supervision, training, hiring, and retention, wrongful death and failure to furnish/summon medical care.

Specifically, the decedent was experiencing mental health issues and required psychiatric treatment. On several occasion from 2009 to 2010, decedent was involuntarily hospitalized pursuant to California law at a county mental health facility. In 2010, the decedent was jailed multiple times. The last time he was jailed, a judge ordered his transfer to a hospital for treatment but the jail did not transfer him. After being placed in solitary confinement and denied treatment at the jail for four weeks, he committed suicide in his cell.

Since that time, the Sutter County Grand Jury issued a report finding, among other things, that the Jail has known deficiencies with relation to its provision of mental health care and medical treatment to inmates. For example, the Grand Jury found deficiencies such as inadequate medical staffing, lack of required training on suicide prevention and other medical treatment, non-compliant medical policies and procedures and a non-compliant medical program. According to the Grand Jury, those deficiencies were "unacceptable." Plaintiffs also allege that, since Decedent's death, several other inmates have also passed away from preventable causes.

On January 9, 2012, Magistrate Judge Gregory Hollows issued an opinion granting in part and denying in part the defendant Sutter County's motion for a protective order and for temporary state of discovery. Magistrate Hollows ordered immediate discovery regarding the identities of potential defendants but stayed all remaining discovery for thirty days. 2012 WL 94618, (E.D. Cal. Jan. 9, 2012).

On February 8, 2012, Judge Morrison England issued an opinion granting the defendants' motion to dismiss the plaintiffs' first amended complaint with leave to amend. 2012 WL 423704 (E.D. Cal. Feb. 8, 2012). The plaintiffs amended their complaint.

Again, the defendants moved to dismiss each of the plaintiffs' claims. On August 31, 2012, Judge England issued an opinion granting the defendants' motion in part and denying it in part. Judge England did not dismiss the all of the deliberate indifference claims, the loss of parent/child relationship claim, the professional negligence/medical malpractice claim, the negligence claim, the failure to furnish/summon medical care claim, and the wrongful death claim. Judge England did dismiss the Title II of the ADA claims, the Section 504 of the Rehabilitation Act claim, the state law civil rights claim, and the negligent supervision, training, hiring and retention claim. 2012 WL 3778953 (E.D. Cal. Aug. 31, 2012). Following this order, the parties went through discovery and preparations for the trial. The parties also entered into settlement negotiations.

On July 22, 2014, the parties reached a private settlement agreement and agreed to dismiss the case. The County agreed to pay $800,000 and promised to consider expert recommendations to improve the treatment of prisoners with serious mental illness and medical conditions at the jail going forward. On September 4, 2014, Judge England dismissed the case.

Jessica Kincaid - 10/30/2015


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Equal Protection
Defendant-type
Corrections
Jurisdiction-wide
Disability
Mental impairment
Discrimination-basis
Disability (inc. reasonable accommodations)
General
Administrative segregation
Classification / placement
Failure to supervise
Failure to train
Suicide prevention
Medical/Mental Health
Mental health care, general
Self-injurious behaviors
Suicide prevention
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action State law
Section 504 (Rehabilitation Act), 29 U.S.C. § 701
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
42 U.S.C. § 1983
Defendant(s) California Department of Mental Health
County of Sutter
Plaintiff Description Estate of an inmate with serious mental illness who committed suicide while in the County's jail
Indexed Lawyer Organizations Rosen, Bien, Galvan & Grunfeld
Class action status sought No
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Attorneys fees
Damages
Source of Relief Settlement
Form of Settlement Private Settlement Agreement
Order Duration 2014 - n/a
Case Closing Year 2014
Case Ongoing No
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)
2:11-cv-536 (E.D. Cal.) 09/04/2014
JC-CA-0120-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Violations of Civil Rights, Americans with Disabilities Act, Section 504, and State Law 02/24/2011
JC-CA-0120-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order 01/09/2012 (2012 WL 94618) (E.D. Cal.)
JC-CA-0120-0004.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum and Order 02/08/2012 (2012 WL 423704) (E.D. Cal.)
JC-CA-0120-0003.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum and Order 08/30/2012 (2012 WL 3778953) (E.D. Cal.)
JC-CA-0120-0007.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Fifth Amended Complaint for Violation of Civil Rights and State Law 03/28/2014
JC-CA-0120-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Plaintiffs' Notice of Filing of Recommendations to Improve Care and to Avoid Preventable Deaths at Sutter County Jail 07/02/2014
JC-CA-0120-0008.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Stipulation of Dismissal With Prejudice 07/22/2014
JC-CA-0120-0005.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Granting Stipulation of Dismissal With Prejudice 09/03/2014 (E.D. Cal.)
JC-CA-0120-0006.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges England, Morrison C. Jr. (E.D. Cal.)
JC-CA-0120-0003 | JC-CA-0120-0006 | JC-CA-0120-0007 | JC-CA-0120-9000
Hollows, Gregory G. (E.D. Cal.) [Magistrate]
JC-CA-0120-0004
Newman, Kendall J (E.D. Cal.) [Magistrate]
JC-CA-0120-9000
Monitors/Masters None on record
Plaintiff's Lawyers Bien, Michael W. (California)
JC-CA-0120-0002
Fischer, Aaron Joseph (California)
JC-CA-0120-0001 | JC-CA-0120-0002 | JC-CA-0120-0002 | JC-CA-0120-0005 | JC-CA-0120-0008 | JC-CA-0120-9000
Galvan, Ernest (California)
JC-CA-0120-0001 | JC-CA-0120-0002 | JC-CA-0120-0002 | JC-CA-0120-9000
Green, Geri L. (California)
JC-CA-0120-0001 | JC-CA-0120-9000
Mantoan, Kathryn Grzenczyk (California)
JC-CA-0120-0002
Rifkin, Lori Ellen (California)
JC-CA-0120-9000
Stark, Jennifer L (California)
JC-CA-0120-0002 | JC-CA-0120-0002 | JC-CA-0120-9000
Defendant's Lawyers Whitefleet, John Robert (California)
JC-CA-0120-0005 | JC-CA-0120-9000
Other Lawyers None on record

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