Steel v. Alameda County Sheriff's Office

Background

Candace Steel was held before trial at Santa Rita Jail after being arrested on misdemeanor charges. She was visibly pregnant and told hospital staff and jail medical personnel about her lack of prenatal care, recent substance use, prior pregnancy-related seizures, uncertainty about her due date, and other medical conditions. About 60 hours after entering the jail, she reported severe pain and difficulty walking. A medical provider concluded that she had a stomachache and was exaggerating her distress. Deputies then moved her to an isolation cell, where she gave birth alone. Baby H was born with the umbilical cord around her neck and initially was not breathing; Steel tried to stimulate the baby’s breathing before deputies entered after hearing the baby cry.

Steel and Baby H sued the Alameda County Sheriff’s Office, Alameda County, individual defendants, and the California Forensic Medical Group (CFMG), which had a contract with Alameda County to provide jail medical services. CFMG answered the complaint and was not a party to the motion addressed in this order. The Alameda County defendants moved to dismiss the first amended complaint under Federal Rule of Civil Procedure 12(b)(6), arguing primarily that the complaint did not plausibly allege a government policy, custom, or practice required for municipal liability under Section 1983.

Section 1983 claims

The court held that the Sheriff’s Office was a proper defendant for a Section 1983 claim. It also held that the complaint plausibly alleged a government policy or practice. According to the complaint, the contract made CFMG responsible for the full cost of hospital services, including labor and delivery, without reimbursement from the Sheriff’s Office. The court found that these allegations plausibly described a financial incentive to withhold inpatient hospital care and that the contract could represent official policy.

The court also held that the complaint plausibly alleged deliberate indifference. The complaint alleged that Santa Rita Jail lacked labor-and-delivery facilities and that CFMG staff were not trained to care for women in childbirth. It also alleged that a state regulation required a pregnant inmate in labor to be treated as an emergency and transported by ambulance to an outside facility. The court concluded that the alleged contract and the defendants’ treatment of Steel plausibly supported the civil-rights claims for inadequate medical care under the Fourteenth Amendment. The same standards applied to Baby H’s Section 1983 claims because she was in the Sheriff’s Office’s custody and her claims rested on the same constitutional protections.

State-law claims

The court dismissed the intentional-infliction-of-emotional-distress claims against the Alameda County defendants because California Government Code § 845.6 immunized them from the alleged injuries. The court concluded that deputies had summoned medical care by asking a CFMG nurse to examine Steel, even though the nurse allegedly provided inadequate care. The court dismissed these claims with leave to amend.

The court also dismissed the negligence-per-se claim with leave to amend. The complaint relied on a regulation requiring a treatment and care plan within seven days of arrival, but Steel allegedly gave birth less than a week after entering the jail. The court found that the complaint did not show that the regulation required a plan before the seven-day deadline.

Disposition

The court stated that the motion to dismiss was granted and denied in part. Steel and Baby H’s Section 1983 claim against the Sheriff’s Office would go forward. The unopposed Fourth Amendment causes of action were dismissed with prejudice. All other claims against the Alameda County defendants were dismissed with leave to amend. Plaintiffs could file an amended complaint by February 3, 2020, but could not add new claims or defendants without prior court approval. Judge James Donato issued the order.