Matilton v. County of Humboldt

Background

The plaintiffs are the children of Eric Matilton, Sr. The complaint alleged that Mr. Matilton had a long history of severe mental illness and entered another person’s home on November 3, 2023, while speaking nonsensically and swinging a baseball bat. He was arrested and booked at the Humboldt County Correctional Facility. The complaint alleged that he received no antipsychotic medication for several days despite having a prescription for Seroquel.

On November 6, Mr. Matilton reported hopelessness, suicidal thoughts, and a desire to die, so facility staff placed him in a safety cell. On November 7, Dr. Christian Agricola evaluated him and noted suicidal thoughts, auditory hallucinations commanding self-harm, a history of self-harm, poor impulse control, and poor judgment and ability to participate in treatment decisions. Dr. Agricola removed Mr. Matilton from the safety cell based on his agreement to take Seroquel.

The complaint alleged that Mr. Matilton missed roughly half of his Seroquel doses between November 7 and November 17, including by refusing the medication and flushing it down the toilet. The plaintiffs alleged that Dr. Agricola knew, or should have known, that Mr. Matilton was not taking the medication regularly but did not take further action. On November 17, Mr. Matilton attempted suicide by asphyxiation in his cell. He was found unconscious and later died from his injuries.

The complaint asserted six causes of action, including claims against Dr. Agricola for violating Mr. Matilton’s Fourteenth Amendment right to medical care, failing to furnish medical care under California Government Code section 845.6, and neglecting a dependent adult under California Welfare and Institutions Code section 15610.57. Dr. Agricola moved to dismiss the Fourteenth Amendment and dependent-adult-neglect claims.

Fourteenth Amendment claim

The court held that the plaintiffs adequately stated a pretrial detainee medical-care claim under the Fourteenth Amendment. At the motion-to-dismiss stage, the court accepted the complaint’s well-pleaded factual allegations as true and viewed reasonable inferences in the plaintiffs’ favor.

The court applied the Ninth Circuit’s four-part standard: the defendant must have intentionally made a decision about the detainee’s confinement conditions; those conditions must have created a substantial risk of serious harm; the defendant must have failed to take reasonable available measures despite the obvious risk; and that failure must have caused the injury.

The court concluded that the allegations met that standard. Dr. Agricola intentionally removed Mr. Matilton from the safety cell. According to the complaint, Mr. Matilton was experiencing a mental breakdown, had suicidal thoughts, and lacked the judgment to make appropriate health decisions, creating a substantial risk of self-harm. The plaintiffs also alleged that Dr. Agricola took no action to ensure that Mr. Matilton took Seroquel or to return him to the safety cell after learning that he was missing doses. The court found these allegations sufficient to support an inference that Dr. Agricola acted with reckless disregard for the risk and that the failure to take protective measures contributed to Mr. Matilton’s suicide attempt and death.

The court rejected Dr. Agricola’s argument that the allegations about his knowledge of the missed doses were contradictory because other staff allegedly failed to notify anyone. The court explained that Dr. Agricola could have learned about the missed doses from records documenting Mr. Matilton’s refusals or by other means. The Fourteenth Amendment claim may proceed.

Dependent-adult-neglect claim

The court dismissed the dependent-adult-neglect claim against Dr. Agricola. California law defines neglect to include the negligent failure of a person having the care or custody of a dependent adult to exercise the care that a reasonable person in a similar position would exercise.

The court explained that “care or custody” requires a robust, ongoing caretaking or custodial relationship involving significant responsibility for one or more of the dependent adult’s basic needs. A person whose involvement is only limited, intermittent, or episodic does not meet that requirement.

The complaint alleged only one interaction between Dr. Agricola and Mr. Matilton, followed by awareness that Mr. Matilton was not regularly taking Seroquel. The complaint also stated that another defendant, Kelsey Hawk, controlled and had final authority over Mr. Matilton’s mental-health care. The court concluded that one evaluation followed by medication monitoring did not establish the required ongoing caretaking relationship. The fact that Dr. Agricola may have had authority to place Mr. Matilton in, or remove him from, a safety cell did not by itself show that he had substantial and ongoing responsibility for Mr. Matilton’s safety.

Because additional facts about Dr. Agricola’s involvement might cure the deficiency, the court granted the plaintiffs leave to amend. The plaintiffs were given 21 days from issuance of the order to amend this claim.

Disposition

The court granted in part and denied in part Dr. Agricola’s motion to dismiss. The California dependent-adult-neglect claim was dismissed against Dr. Agricola, with 21 days to amend. The Fourteenth Amendment claim against Dr. Agricola may proceed. The order was signed by United States Magistrate Judge Robert M. Illman.