On October 30, 2008, a pre-trial detainee of the Los Angeles City Central Jail filed a pro se complaint in the U.S. District Court for the Central District of California against Los Angeles County officials, the Los Angeles County Sheriff, and a medical doctor that served the jail. The plaintiff alleged that the conditions of confinement, specifically lack of a bed and infestation, violated his constitutional rights. Additionally, the plaintiff alleged he was denied prompt medical care when the defendant doctor failed to supply prescribed medication for 43 days. The plaintiff sought compensatory damages in the amount of $33,000 and punitive damages in the amount of $333,000.
The plaintiff had entered jail custody in July 2006, and as he was being processed, there was a string of racially charged violent disturbances at several jail facilities. Officials locked down multiple facilities, which delayed in-processing. As a result, the plaintiff was held at a facility without sufficient bench space for sleeping, and no beds or mattresses. He slept on the floor.
On November 9, 2009, the defendants filed a motion to dismiss on the grounds that the plaintiff failed to exhaust his administrative remedies, which the Magistrate Judge Alicia G. Rosenberg recommended be granted in part and denied in part. On June 6, 2010, the District Court (Judge John F. Walter) adopted the Magistrate Judge's report and dismissed all claims except the claim against the Sheriff in his individual and official capacities for failure to provide adequate sleeping accommodations.
On September 14, 2010, the plaintiff filed a second amended complaint against the Los Angeles County Sheriff in his official and individual capacities, alleging substantively the same claims for conditions of confinement. In response to the defendants' motion to dismiss the Second Amended complaint, the District Court dismissed all claims except the claim against the Sheriff in his individual capacity for failure to provide adequate sleeping conditions.
On April 30, 2013, the defendant filed a motion for summary judgment on the remaining claim. A magistrate judge found that the newly supplemented record demonstrated that the Los Angeles County jail had faced difficult exigent circumstances in the aftermath of the disturbances and lockdown, and that this meant there had been no constitutional violation. The District Court agreed, dismissing the case on July 18, 2013. 2013 WL 3791419.
Plaintiff appealed, and On July 30, 2013, the plaintiff filed a notice of appeal to the Ninth Circuit. After appointing counsel to represent the plaintiff pro bono, on January 11, 2019, the Court of Appeals affirmed in an opinion by Judge Consuelo Callahan. Olivier v. Baca, 913 F.3d 852 (9th Cir. 2019). In light of the exigent circumstances, the opinion explained, there was no constitutional violation--and the sheriff was entitled to qualified immunity.
Anjali Biala - 11/07/2013
Will McCartney - 03/22/2018
- 11/04/2019
compress summary
