Saxton v. County of Sonoma
- Susan Illston
- 3:21-cv-09499
- U.S. District Court · Northern District of California
- 4
In Saxton v. County of Sonoma, Judge Illston granted defendants’ motion to dismiss one Section 1983 claim and denied the rest.
The Saxton plaintiffs and the defendants, including the County of Sonoma and Sheriff Essick; the first cause of action was dismissed at the pleading stage, while the remaining challenged claims were allowed to proceed.
What happened
Saxton v. County of Sonoma concerns allegations that jail staff failed to prevent fentanyl from entering the Main Adult Detention Facility, where Marcotte was housed, and failed to respond to warning signs before two people overdosed.
The court held that the first claim did not adequately allege that officials knew of and disregarded a serious risk to Marcotte’s safety. The court therefore granted the motion to dismiss that claim.
Judge Susan Illston denied the remainder of the motion, finding the complaint sufficient at the pleading stage on the failure-to-train, negligence, and negligent-hiring claims. The defendants may raise those arguments again on summary judgment.
The detailed version
- Saxton v. County of Sonoma · No. 3:21-cv-09499
- Susan Illston
- Sept. 12, 2024
Background
The Saxton plaintiffs brought a claim under 42 U.S.C. § 1983 alleging that the defendants failed to intervene to prevent fentanyl from being smuggled into Sonoma County’s Main Adult Detention Facility. The complaint alleged that jail staff knew fentanyl was being held in the booking area, observed interactions involving Tiffany Pimentel, Frankie Thompson, and Bianca Navarro, and failed to conduct follow-up investigation, review available video, or search Pimentel’s cell. It further alleged that these failures could have prevented Amber Marcotte’s death.
First Cause of Action
The defendants argued that the complaint failed to state a claim because it did not adequately allege deliberate indifference under the Eighth Amendment. The court concluded that, because Marcotte had entered a plea when she died, she should be treated as a convicted prisoner rather than as a pretrial detainee. Under the Eighth Amendment standard, an official must know of and disregard an excessive risk to an inmate’s health or safety.
The court found that the allegations did not show that any deputy knew that Thompson and Navarro had given fentanyl to Pimentel, that Pimentel had given fentanyl to Marcotte, or that Marcotte had ingested fentanyl. The allegations therefore did not show that an official was aware of facts from which the official could infer a substantial risk of serious harm to Marcotte. The court granted defendants’ motion to dismiss the first cause of action.
Remaining Issues and Disposition
The defendants also argued that Sheriff Essick was entitled to qualified immunity on the third cause of action, which alleged failure to train under § 1983, and that all defendants were entitled to dismissal of the negligence and negligent-hiring claims. The court concluded that the first amended consolidated complaint was sufficient as a pleading and denied the balance of the motion. The defendants may raise those arguments on summary judgment.
The order does not state whether the first cause of action may be amended or whether its dismissal is with or without prejudice.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.