Mendiola-Martinez v. Arpaio

Plaintiff was in the custody of Maricopa County for a nonviolent offense when she gave birth to her son. After her release, she filed suit under 42 U.S.C. 1981 & 1983, alleging that her constitutional rights were violated when, among other things, she was shackled and restrained during labor and postpartum recovery. The district court granted summary judgment for the County Defendants and the Medical Center on all of plaintiff's claims, and taxed costs against her. The court addressed an issue of first impression: whether the U.S. Constitution allows law enforcement officers to restrain a female inmate while she is pregnant, in labor, or during postpartum recovery. The court held that, in this case, the answer to that question depends on factual disputes a properly instructed jury must resolve. Therefore, the court vacated and remanded the district court’s grant of summary judgment for the County Defendants on most of plaintiff's shackling claims. The court affirmed the grant of summary judgment in favor of the County Defendants on the remaining claims, and affirmed summary judgment on all claims against the Medical Center. The court vacated the cost award to the County Defendants and remanded, but the court affirmed the cost award to the Medical Center. View "Mendiola-Martinez v. Arpaio" on Justia Law