Hydrick v. Hunter

In order to seek monetary damages under a § 1983 claim, a plaintiff must overcome qualified immunity by alleging factual allegations that are sufficient to establish a plausible claim against a defendant.

Civilly committed persons ("plaintiffs") filed a § 1983 suit against administrators of the Atascadero State Hospital in Atascadero, California ("defendants") alleging constitutional violations in relation to their civil commitments under California's Sexually Violent Predator Act. Defendants initially moved to dismiss all claims seeking monetary damages based upon their qualified immunity. The district court denied defendant's motion and defendant's filed an interlocutory appeal to the Ninth Circuit. The Ninth Circuit initially affirmed in part and reversed in part, and defendant's petitioned the Supreme Court for certiorari. The Supreme Court vacated the Ninth Circuit's decision, and remanded the case to be re-evaluated in light of Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009). On remand the Ninth Circuit held that plaintiff's allegations were not sufficiently specific to establish plausible claims against the defendants, as plaintiffs never alleged any specific policy or event by the defendants that led to the alleged constitutional violations. Therefore, defendants were entitled to qualified immunity from monetary damages. The Ninth Circuit also noted that plaintiff's claims seeking injunctive and declaratory relief may continue, as qualified immunity does not prohibit those claims. REVERSED and REMANDED.