Masterson v. County of Alameda

Background

The plaintiffs are survivors of Logan Masterson, who died by suicide while an inmate at Santa Rita Jail. The complaint alleges that he was arrested, brought to the jail, moved to an isolation cell, and remained there until his self-inflicted hanging death on April 6, 2018.

Tiffany Masterson sued in her personal capacity and as executor of the decedent’s estate. The decedent’s minor children also sued through guardians ad litem. The defendants included Alameda County; Sheriff Gregory Ahern; Deputy Nicholas Lagorio; Sergeant Joshua Pape; County behavioral-health officials and providers; California Forensic Medical Group; and three nurses.

The First Amended Complaint asserted eight claims: three claims under 42 U.S.C. § 1983 alleging violations of the Fourteenth Amendment; medical malpractice; failure to furnish medical care; negligent supervision; wrongful death; and negligence. The County Defendants moved to dismiss all claims against them except the medical-malpractice and wrongful-death claims.

Court’s analysis

The court applied the standard for dismissal under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. The court explained that a complaint must provide enough factual allegations to make liability plausible, rather than relying only on legal conclusions.

For claims one through three, the plaintiffs agreed to dismissal of their § 1983 claims against Ahern and Burton in their official capacities. The court therefore dismissed those claims as to those defendants in those capacities. The court rejected the County Defendants’ argument that the complaint failed to plead a basis for liability under Monell v. Department of Social Services. It held that the amended complaint adequately alleged § 1983 claims based on policies and practices against the County, Ahern in his individual capacity, and Burton in her individual capacity. The court also rejected the argument that supervisors cannot be liable without direct, personal interaction with the plaintiff.

For claims five, six, and eight, the court found that the complaint did not adequately plead the required statutory duty for claims against a public entity and did not clearly identify the factual allegations, conduct, and responsible actors supporting each negligence theory. The court allowed the plaintiffs to plead alternative theories of liability at this stage and dismissed these three claims against the County Defendants with leave to amend.

Disposition

The court granted the motion to dismiss the first, second, and third claims as asserted against Ahern and Burton in their official capacities. It denied the motion to dismiss those claims as asserted against the County, Ahern in his individual capacity, and Burton in her individual capacity. It granted the motion to dismiss the fifth, sixth, and eighth claims against the County Defendants with leave to amend. The order states that the plaintiffs were to file an amended pleading by January 10, 2020, and that defendants were to answer by January 31, 2020.