Castro v. County of Los Angeles

Individual defendants are not entitled to qualified immunity when a constitutional protection is established at the time of the incident, and when sufficient evidence shows that the defendants were deliberately indifferent to a substantial risk of harm to the plaintiff.

Jonathan Castro was detained for being drunk in public and held at the Los Angeles Sheriff’s West Hollywood Station. During his detention in a sobering cell, Castro was attacked by another intoxicated detainee, and suffered serious and ongoing harm. Castro brought federal and state law claims against the County of Los Angeles, the Los Angeles County Sheriff’s Department, and two police officers as individuals. The jury held for Castro against all defendants. The defendants filed a joint motion for judgment as a matter of law following the jury verdict, which the district court denied. The defendants then appealed all of the federal claims, arguing they were entitled to qualified immunity for government officials against civil liability. The Ninth Circuit held that the individual defendants were not entitled to qualified immunity because the constitutional protection of freedom from violence at the hands of other inmates was established at the time of the incident, and sufficient evidence showed that the defendants “were deliberately indifferent to a substantial risk of harm” to Castro. Deliberate indifference is defined as a “conscious choice to disregard the consequences of one’s acts or omissions.” The panel found that the individual defendants’ deliberate indifference included housing Castro with a combative individual when other cells were empty, failing to respond to pounding on the cell window, and delegating safety checks to a volunteer. The panel failed to find whether the County or police department were also deliberately indifferent. Therefore, the panel affirmed the judgments against the individual defendants, but reversed the judgment against the County. AFFIRMED in Part and REVERSED in Part.