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, sought damages, claiming violations of the Eighth and Fourteenth Amendments to the U.S. 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 attorneys' fees. 2014 WL 8390755 (C.D. Cal. Dec. 29, 2014).

In the district court, the plaintiffs moved to retax costs and to award nontaxable expenses on May 15, 2015. They sought a total of $89,648.64. On November 12, 2015, the court denied the plaintiffs' motion to retax costs and granted their motion to award nontaxable costs of $39,928.35.

On May 30, 2018, the Ninth Circuit (Circuit Judges William A. Fletcher and Sandra S. Ikuta, and District Judge Sarah Evans Barker, sitting by designation) affirmed the district court's judgment in favor of plaintiffs, award of compensatory and punitive damages, and award of attorneys' fees. 891 F.3d 776 (9th Cir. 2018). Specifically, the panel denied the defendants' request to vacate the final judgment on the basis that the district court lacked jurisdiction. Regarding the exhaustion of administrative remedies, the panel held that the district court did not clearly err in finding that a reasonable fear of retaliation made the grievance system effectively unavailable for appellees. Additionally, the panel found that the district court did not err in denying the defendants' motion for judgment as a matter of law based on qualified immunity: there was sufficient evidence of a constitutional violation and the law was clearly established. The supervisors were not entitled to qualified immunity or immunity under state law. Further, the panel held that the record supported the jury's verdict and the district court's ruling of municipal liability. Finally, the panel upheld the jury's award of punitive damages and the district court's attorneys' fee award.

The parties agreed that the plaintiffs will be paid an additional $825,000.00 in attorneys' fees and costs relating to the appeal. The parties also agreed that the plaintiffs were owed post-judgment interest on compensatory damages, punitive damages, attorneys' fees, and costs. Thus, the final total amount of the judgment was $7,289,973.77.

Jessica Kincaid - 10/30/2015
Eva Richardson - 01/04/2019


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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 42 U.S.C. § 1983
State law
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
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Attorneys fees
Damages
Source of Relief Litigation
Filing Year 2010
Case Ongoing No reason to think so
Docket(s)
2:10-cv-06342 (C.D. Cal.)
JC-CA-0111-9000.pdf | Detail
Date: 12/07/2018
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Damages for Violations of Federal Civil Rights (Eighth and Fourteenth Amendment) [ECF# 1]
JC-CA-0111-0001.pdf | Detail
Date: 08/25/2010
Source: PACER [Public Access to Court Electronic Records]
Second Amended Complaint for Damages for Violations of Federal Civil Rights (Eighth and Fourteenth Amendment) [ECF# 76]
JC-CA-0111-0002.pdf | Detail
Date: 09/26/2011
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 [ECF# 202] (C.D. Cal.)
JC-CA-0111-0003.pdf | Detail
Date: 02/25/2013
Source: PACER [Public Access to Court Electronic Records]
Order Denying Motions for Summary Judgment, Granting Motion for Joinder, and Granting Motion in Limine [ECF# 261] (C.D. Cal.)
JC-CA-0111-0004.pdf | Detail
Date: 07/12/2013
Source: PACER [Public Access to Court Electronic Records]
Plaintiffs' Memorandum of Contentions of Fact and Law [ECF# 295]
JC-CA-0111-0005.pdf | Detail
Date: 07/29/2013
Source: PACER [Public Access to Court Electronic Records]
Defendant Hernan Delgado's Memorandum of Contentions of Fact and Law [ECF# 297]
JC-CA-0111-0006.pdf | Detail
Date: 07/29/2013
Source: PACER [Public Access to Court Electronic Records]
Judgment [ECF# 626] (C.D. Cal.)
JC-CA-0111-0007.pdf | Detail
Date: 02/05/2014
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... [ECF# 693] (2014 WL 8396787) (C.D. Cal.)
JC-CA-0111-0008.pdf | WESTLAW | Detail
Date: 05/29/2014
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 [ECF# 750]
JC-CA-0111-0009.pdf | Detail
Date: 06/26/2014
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 [ECF# 751]
JC-CA-0111-0010.pdf | Detail
Date: 06/26/2015
Source: PACER [Public Access to Court Electronic Records]
Opinion [Ct. of App. ECF# 114] (891 F.3d 776)
JC-CA-0111-0012.pdf | WESTLAW| LEXIS | Detail
Date: 05/30/2018
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
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

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