Flores v. County of Los Angeles

Under 42 U.S.C. § 1983, a plaintiff must show that the lack of training is the proximate cause of an assault.

When Maria Flores received a traffic ticket, she went to the Los Angeles County Vehicle inspection site to clear the ticket. When Flores was there, she claims that a deputy sheriff, who was on duty at the time, sexually assaulted her. Flores later sued the County along with the sheriff under 42 U.S.C. § 1983, arguing that her assault was “a proximate result of their failure properly to train deputy sheriffs ‘to ensure that Sheriff’s [d]eputies do not sexually assault women that [d]eputies come in contact with.’” The district court dismissed her case, stating that Flores failed to state a claim. Flores on appeal argued that the County failed to provide the proper training for the officers employed in that county to ensure that the deputies do not sexually assault women. The Ninth Circuit held that under 42 U.S.C. § 1983, a person acting under color of law shall be held liable to the party that has suffered harm under the Constitution. Moreover, state and local officials will not be held liable for the deprivation of Constitutional rights that has been committed by employees. The panel found that Flores must show, under 42 U.S.C. § 1983, that the sheriffs “disregarded the known or obvious consequences that a particular omission in their training program would cause [municipal] employees to violate citizens’ constitutional rights.” The panel also found that Flores failed to “allege sufficiently that the failure to train sheriff’s deputies not to commit sexual assault constitutes deliberate indifference to the risk of such assault by a deputy.” The panel ultimately found that Flores did not allege sufficient facts to state a claim against the County or the sheriff. AFFIRMED.