Papia v. County of Marin

Background

Angelina Papia sued the County of Marin, the Marin County Sheriff's Office, Sheriff Jamie Scardina, the County of Marin Department of Health and Human Services, Anthony Baylacq, and Doe Defendants concerning the death of Papia's son, Dylan Baylacq, while he was in custody at the Marin County Jail. The complaint asserted claims under 42 U.S.C. § 1983, a federal civil-rights statute, and California state law. The County and Sheriff Scardina moved to dismiss.

Municipal-liability claims

The court held that the complaint did not plausibly allege a claim against the County under § 1983. A government entity can be liable under that statute when its policy, practice, or custom is the moving force behind a constitutional violation. Papia alleged that defendants placed Dylan Baylacq in danger through a policy, procedure, and practice, but she did not provide facts supporting a plausible inference that such a policy or procedure existed or that a persistent and widespread practice caused the alleged violation. The court also explained that it could not consider new facts raised only in Papia's opposition to the motion rather than in the complaint.

The court dismissed claims 1 through 5 with leave to amend.

Supervisory-liability claim

The court also dismissed Papia's supervisory-liability claim against Sheriff Scardina with leave to amend. A supervisor may be liable under § 1983 if the supervisor personally participated in the constitutional violation or if there is a sufficient causal connection between the supervisor's wrongful conduct and the violation. Papia alleged that Sheriff Scardina directed subordinates to violate Dylan Baylacq's rights, but she did not allege facts showing that he was personally involved, was present when Dylan was booked, participated in the decision to place him in a special housing unit rather than a suicide-resistant safety cell, or had a sufficient causal connection to the alleged violation.

State-law claims

The court declined to exercise supplemental jurisdiction, meaning its authority over related state-law claims, until Papia pleaded valid federal claims. It therefore did not decide whether the state-law claims were sufficiently pleaded or whether defendants were immune from liability under California law. The court stated that it would consider the state-law immunity argument if Papia adequately alleged federal claims in an amended complaint.

Disposition

The court vacated the scheduled hearing and granted defendants' motion to dismiss with leave to amend. The First Amended Complaint was dismissed with leave to amend. Any further amended complaint had to be filed by March 31, 2025. The order disposed of Docket No. 17.