Horton v. City of Santa Maria

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Plaintiff filed suit under 42 U.S.C. 1983 and California law, alleging that the city, the police department, and individual officers violated his Fourteenth Amendment right to be safeguarded from injury and his state law right to medical care while in custody. Plaintiff tried to commit suicide while he was a pretrial detainee and now suffers permanent and severe brain damage. The Ninth Circuit reversed the district court's denial of qualified immunity on the section 1983 claims as to Officer Andrew Brice, because it was not clearly established at the time that a reasonable officer would perceive a substantial risk that plaintiff would imminently attempt suicide. The panel held that it lacked jurisdiction to review the denial of summary judgment on the section 1983 claims as to the municipal defendants, because the pendent Monell claim was not inextricably intertwined with a properly reviewable collateral appeal, as the panel's resolution of Officer Brice's appeal from the denial of summary judgment on qualified immunity did not "necessarily" resolve plaintiff's Monell claim. Finally, the panel affirmed the district court's denial of summary judgment on the state law claims, because a reasonable jury could conclude that Officer Brice had reason to know that plaintiff had a serious medical condition and required immediate medical care and he failed timely to summon such care. The panel remanded for further proceedings. View "Horton v. City of Santa Maria" on Justia Law