Gonzalez v. Ahern

Background

Plaintiffs, identified as current and former inmates at Santa Rita Jail, brought a proposed class action under Section 1983, a federal law allowing claims against state actors for violations of constitutional rights. They sued Alameda County, the Alameda County Sheriff’s Office, Sheriff Gregory J. Ahern, detention officials, four deputies, Wellpath Management, Inc., and Aramark Correctional Services LLC. The County Defendants and Aramark separately moved to dismiss the second amended complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Plaintiffs alleged unconstitutional conditions involving food, commissary and other fee-based services, sanitation, medical care, enforced idleness and group punishment, grievance practices, language services, attorney visits, and responses to COVID-19. They asserted eleven claims involving the First, Eighth, Sixth, and Fourteenth Amendments, Title VI of the Civil Rights Act of 1964, and alleged profiteering.

Court’s Analysis and Rulings

The court found that plaintiffs had again failed to connect many claims to wrongdoing by particular defendants and had not provided facts supporting the full breadth of their allegations. Because Sheriff Ahern, Tom Madigan, Captain Luckett-Fahima, Waldura, and Diaz were sued only in their official capacities, and the County was also named, the court dismissed those officials as redundant defendants.

First Amendment claim. The court granted the motion as to the general challenge to the jail’s grievance process because prisoners have no constitutional right to a particular grievance procedure. But the court held that Plaintiff Gerrans adequately alleged retaliation for filing grievances. Gerrans alleged that after he submitted collective grievances, he was removed from the jail to silence and intimidate prisoners. The court denied the motion as to that retaliation theory against the County, the Sheriff’s Office, and Hesselein in his individual capacity. The court granted the motion as to the remaining First Amendment allegations, including the allegations about interference with family communications.

Medical-care claims. Plaintiffs asserted Eighth and Fourteenth Amendment claims against the County and Wellpath based on alleged cost-reduction policies, and individual-capacity claims against Deputies Ignot and Joe. The court concluded that most of the medical-care incidents were not tied to the alleged financial-incentive policy and that plaintiffs therefore had not adequately pleaded municipal liability. The court also found that Gerrans lacked standing to pursue the claim based on the unnamed young man’s treatment because Gerrans was not alleged to have suffered the same injury. The court granted the motion to dismiss the inadequate-medical-care claims.

Food claims. Plaintiffs alleged that jail food was nutritionally poor, contaminated, and prepared in unsanitary conditions. The court found that allegations about rodents, birds, feces, foreign objects, and inadequate kitchen sanitation were sufficient at the pleading stage to allege a serious risk to prisoners’ health and safety and a practice supporting claims against the County and Aramark. It denied the motion as to the food claims based on contamination and unsanitary conditions. It granted the motion as to claims based only on nutritional content, while allowing plaintiffs to amend if they could allege specific facts showing that the nutritional content was constitutionally deficient.

Sanitation claims. Plaintiffs alleged limited access to cleaning supplies, inadequate cleaning equipment, restricted toilet access, and resulting infections. The court held that these allegations were sufficient to state inadequate-sanitation claims. It denied the motion as to the County and as to Gerrans’s individual-capacity claims against Deputies Ignot and Joe, based partly on allegations that an ill man was left in a communal cell for more than 15 hours while feces contaminated the area.

Sixth Amendment claim. Plaintiffs alleged that defendants interfered with attorney-client communications and visits. The court held that the complaint did not identify who denied legal visits, establish a policy or procedure causing the denials, or allege deliberate interference that substantially prejudiced the attorney relationship. It dismissed the claim with leave to amend if plaintiffs could plead those facts.

Punishment claim. Plaintiffs alleged excessive lockdowns, inadequate out-of-cell time and recreation, arbitrary clothing rules, inadequate programming, and enforced idleness. The court found that the allegations were too general and did not provide facts showing deliberate indifference or reckless disregard for health and safety. It dismissed the claim with leave to amend based on specific facts concerning lockdowns and access to exercise.

Title VI claim. Plaintiffs alleged that defendants failed to provide meaningful access to programs for people with limited English proficiency. The court held that a damages claim under Title VI requires an allegation that the entity engaged in racial discrimination and received federal financial assistance. Because plaintiffs had not alleged that the jail received federal financial assistance, the court dismissed the claim with leave to amend.

Profiteering claim. Plaintiffs alleged that the Sheriff’s pursuit of profit caused harmful and inhumane conditions. The court held that an alleged profit motive, by itself, was not a separate Fourteenth Amendment claim and treated the claim as a catch-all for the other constitutional claims. The court granted the motion as to this claim.

Disposition

Judge Jacqueline Scott Corley granted in part and denied in part the motions to dismiss. The motions were denied as to Gerrans’s First Amendment retaliation claim based on his alleged transfer; the food claims against Aramark and the County to the extent based on contamination and unsanitary conditions; and the sanitation claims against the County and Gerrans’s claims against Deputies Ignot and Joe. The motions were granted as to the specified official-capacity defendants, the remaining First Amendment allegations, the medical-care claims, the nutritional-content food claims, the Sixth Amendment claim, the punishment claim, the Title VI claim, and the profiteering claim. The court gave plaintiffs 21 days to file an amended complaint.