Prescott v. Contra Costa County

Background

Emarieay Prescott sued Contra Costa County, the Contra Costa County Sherriff’s Office, and unidentified individual deputies. He alleged that, on March 18, 2020, other inmates attacked him while he was awaiting trial at the West County Detention Facility. Prescott alleged that two deputies saw the attack but did not intervene. He was taken to an emergency room, where he was diagnosed with a fracture around his right eye and given medication.

Prescott further alleged that he continued having difficulty seeing with that eye and submitted several grievance slips seeking another examination. According to the complaint, the slips went unanswered for months. When he eventually received follow-up care, he was told that his eye was permanently damaged. He asserted claims under 42 U.S.C. § 1983, a federal law allowing claims against state or local officials for violating constitutional rights, based on failure to protect him and deliberate indifference to his medical needs under the Fourteenth Amendment.

Motion to Dismiss

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not allege enough facts to state a legally valid claim. They argued that Prescott had not adequately pleaded claims against the County and Sheriff’s Office under Monell, the doctrine governing when a local government may be liable for an official policy, custom, or practice. They also argued that the statute of limitations barred the complaint.

The court stated that California’s two-year limitations period for personal-injury claims applies to § 1983 claims. It also considered California’s tolling provision, which can pause the limitations period for up to two years when a person is imprisoned on a criminal charge or serving a criminal sentence of less than life.

Statute of Limitations

Defendants argued that the limitations period ended no later than March 18, 2022, two years after the alleged attack, while Prescott filed suit on March 18, 2024. Prescott argued that the limitations period was tolled for two years because he was incarcerated when his claims arose.

The parties disputed whether the California tolling provision applies to people held in county jails while awaiting trial, rather than only to people in state prison. The court discussed conflicting authorities, including a Ninth Circuit decision interpreting the provision to cover people held in county jails and a later California Court of Appeal decision interpreting it more narrowly. The court concluded that the Ninth Circuit’s interpretation remained binding and was the better prediction of how the California Supreme Court would interpret the statute. It held that the provision tolled Prescott’s claims for two years while he was continuously in custody.

The court therefore denied the motion to dismiss on the statute-of-limitations ground and concluded that the complaint was not barred at this stage.

Disposition

The court granted the motion to dismiss as to the Monell claims against the County and Sheriff’s Office. It denied the motion to the extent defendants argued that the complaint was barred by the statute of limitations. The court stated that amendment might not be futile and allowed Prescott to file an amended complaint within 21 days of the order. It also set a telephonic case-management conference for August 6, 2024, and directed the parties to submit individual case-management statements by July 30, 2024.