Steward v. County of Santa Clara

Background

Aaron Steward sued the County of Santa Clara, correctional officers, and a nurse over events that occurred while he was a pretrial detainee in Santa Clara County custody. The motion addressed claims arising from a November 7, 2016 strip and cavity search and the contraband watch that followed; the administration of laxatives by Nurse Richard Guerzo; a July 12, 2017 van transport that Steward described as a “rough ride”; and claims that the County had policies or practices that caused constitutional violations.

The defendants moved for summary judgment under Rule 56. Summary judgment is appropriate when the evidence shows no genuine dispute about a fact important to the outcome and the moving party is entitled to judgment as a matter of law. On such a motion, the court must generally accept the nonmoving party’s supported version of disputed facts and draw reasonable inferences in that party’s favor.

Deputy Rico West and the November 7, 2016 Search

Steward asserted federal constitutional and state-law claims against West based on the search and contraband watch. The court granted summary judgment for defendants to the extent the claims were based on the initial visual strip search or West’s participation in the contraband watch. The court found probable cause for the visual strip search based on information from a confidential informant, and the evidence showed that other officers made the decision to conduct that search. The evidence also showed that West was not involved in the contraband watch.

The court denied summary judgment on the claims based on Steward’s allegation that West falsely said he saw contraband protruding from Steward’s rectum and threatened him by saying, “get it out or I will.” Steward said these events occurred before the video began and caused him to digitally penetrate himself. The court found that the video did not conclusively disprove Steward’s account. Accepting his version for summary-judgment purposes, a jury could find that West’s conduct was excessive, vindictive, harassing, or unrelated to a legitimate correctional purpose. The court also ruled that West was not entitled to qualified immunity on the federal claim at this stage.

Nurse Richard Guerzo

The court granted summary judgment on all claims against Guerzo. Steward claimed that Guerzo gave him laxatives without informed consent, failed to ask about medical conditions that could make the medication unsafe, and falsified his medical record by describing him as constipated. The court found no triable issue on the Fourteenth Amendment medical-care claim because Steward did not show that the laxatives created a substantial risk of serious harm or that he suffered injury from them. The court also found that the evidence showed Steward repeatedly agreed to receive a laxative and did not object when he took it.

The court rejected Steward’s argument that administering laxatives amounted to participating in the cavity search. It further held that the alleged use of the word “constipation” in the nursing assessment did not establish a constitutional violation, particularly because Steward did not connect the alleged record error to harm. Because there was no underlying Fourteenth Amendment violation, the court also granted summary judgment on the claim under California’s Bane Act, which concerns interference with rights through threats, intimidation, or coercion.

Deputy Christopher Graham and the “Rough Ride”

Steward alleged that Graham intentionally drove a van in a way that caused Steward, who was shackled and not wearing a seatbelt, to slide and strike his head. The court granted summary judgment on Steward’s federal claim under 42 U.S.C. § 1983 because Steward did not exhaust the available jail grievance process as required by the Prison Litigation Reform Act. Steward did not dispute that he had not filed a grievance about the alleged rough ride.

The court denied summary judgment on the state-law claims against Graham. The court held that Steward’s government tort claim satisfied California’s claims-presentment requirement. It also found a triable factual issue on the Bane Act claim because Steward alleged that Graham intentionally caused him to be tossed around in the van, and defendants submitted no evidence disputing that account. The court likewise found summary judgment unwarranted on the intentional-infliction-of-emotional-distress claim because defendants offered no specific argument explaining why Steward’s evidence was insufficient.

Other Defendants and Doe Defendants

Steward agreed that his claims against Tony Alvarez, Adam Valle, and Amy Le should be dismissed. The court granted defendants’ motion for summary judgment as to those defendants and dismissed the claims against Alvarez, Valle, and Le with prejudice. The court also granted summary judgment on claims against the Doe defendants; the opinion states that Steward’s opposition did not address those claims and that he appeared to have abandoned them.

County Liability

Steward’s claim against the County was based on municipal liability under Monell v. Department of Social Services. That doctrine can hold a local government responsible under § 1983 when an official policy or custom causes a constitutional violation, but not merely because the government employs someone who allegedly acted unlawfully.

The court granted summary judgment on the County’s Monell claim. Steward focused his opposition on the alleged rough ride and argued that the County knew about earlier rough rides but failed to investigate. The court ruled that the declaration supporting this argument was inadmissible on hearsay and relevance grounds and because the witness had not been disclosed. Steward’s remaining evidence was insufficient to show that a County policy or practice caused the alleged violations. The court noted that the individual officers involved were not policymaking employees.

Disposition

The court granted defendants’ motion for summary judgment to the extent it concerned West’s responsibility for initiating the visual strip search or involvement in the contraband watch; all claims against Guerzo, Alvarez, Valle, Le, and the Doe defendants; Graham’s § 1983 claim concerning the rough ride; and the County’s Monell claim. The court denied the motion on West’s federal and state claims based on the alleged false statement and threat leading to the cavity search, and on Graham’s state-law claims concerning the rough ride. Steward’s separate excessive-force claims against West arising from the July 12, 2017 incident were not part of the motion and will proceed to trial. Judge Susan Illston vacated the scheduled hearing and resolved the motion without oral argument.