Castillo v. City of Watsonville

Background

According to the complaint, Robert Castillo expressed suicidal thoughts on November 23, 2018. After he refused voluntary psychiatric services, his family called for emergency help. Watsonville police officers placed him on a 72-hour involuntary psychiatric hold under California law. The next morning, the Santa Cruz Sheriff’s Office informed his family that he had intentionally walked into traffic and apparently died by suicide.

Guadalupe Castillo sued on her own behalf and as an heir to Robert Castillo’s estate. The complaint asserted four claims: two federal constitutional claims under 42 U.S.C. § 1983, one California claim for failing to furnish or summon medical care, and one California wrongful-death claim. The defendants moved to dismiss all claims for failure to state a legally sufficient claim.

Federal claims

The court treated the first § 1983 claim as asserting municipal liability against the City and supervisory liability against Chief Honda. A municipal-liability claim requires allegations that a government policy or custom caused a constitutional violation. The court held that the complaint did not plausibly allege such a policy or custom. The allegations and a 2018 research paper did not identify specific deficiencies in the City’s practices, show a pattern of similar harmful incidents, or establish that City policymakers knew—or should have known—that inadequate crisis-intervention training was substantially certain to cause a constitutional violation.

The court also held that the allegations against Chief Honda were insufficient in his individual capacity. The complaint described his general responsibility for hiring, training, supervising, and setting policies, but did not allege that he was directly involved in the conduct or knew about and accepted the alleged constitutional violations. The official-capacity claim was dismissed as redundant because the City was also named and no injunctive relief was sought.

The second federal claim alleged that the defendants violated Guadalupe Castillo’s constitutional right to familial association. The court explained that this type of claim requires conduct that “shocks the conscience,” a more demanding standard than deliberate indifference. Because the complaint did not adequately allege deliberate indifference to Robert Castillo’s needs, it also did not meet the higher standard for the familial-association claim. The court nevertheless allowed amendment of the claim against the City and Chief Honda in his individual capacity.

State-law claims

The third claim alleged failure to furnish or summon medical care, and the fourth alleged wrongful death. The court treated these claims against Chief Honda as abandoned because Plaintiff did not address them in her opposition to the motion. The court dismissed both claims against Chief Honda without leave to amend.

The City argued that the state-law claims were barred because Plaintiff submitted her government tort claim more than six months after Robert Castillo’s death. Plaintiff relied on California’s delayed-discovery rule, which can postpone accrual until the plaintiff discovers, or has reason to discover, the injury and its alleged wrongful cause. The court held that Plaintiff sufficiently alleged that she did not learn where Robert Castillo had been taken, or that medical care allegedly had not been summoned, until she obtained a coroner’s report and contacted the psychiatric facility in July 2019. Whether she knew or should have known earlier was a factual issue not suitable for resolution on a motion to dismiss.

Disposition

The court granted in part and denied in part the defendants’ motion to dismiss. For the first claim, the motion was granted as to the City and Chief Honda in his individual capacity with leave to amend, and granted as to Chief Honda in his official capacity without leave to amend. For the second claim, the motion was granted as to the City and Chief Honda in his individual capacity with leave to amend, and granted as to Chief Honda in his official capacity without leave to amend. For the third and fourth claims, the motion was denied as to the City and granted as to Chief Honda without leave to amend. Plaintiff could file an amended complaint addressing the identified deficiencies by October 20, 2020, but could not add new claims or parties without permission or the parties’ agreement.