Ahmed v. County of Santa Clara

Background

Abdisamad Ahmed and Kim Hadd sued the County of Santa Clara and individuals whose identities were unknown to them. They sued as heirs to Harris Ahmed and representatives of his estate. The complaint asserted three claims: general negligence, public-entity negligence under California law, and violation of rights under 42 U.S.C. § 1983, a federal civil-rights statute.

The complaint alleged that Harris, the plaintiffs’ 21-year-old son, was admitted to a County-operated medical facility on March 15, 2019, for acute psychiatric services after attempting to run across Interstate 280. According to the complaint, the notice accompanying his admission described him as gravely disabled, unpredictable, agitated, threatening at times, and unable to care for himself. The notice allegedly ordered that he be held until March 29, 2019, but he was released on March 26. The complaint alleged that he displayed the same behavior on the day of his release and, two days later, walked onto Interstate 280, where a vehicle struck and killed him.

The plaintiffs alleged that the County knew or should have known Harris was unfit for early release but failed to prevent it. They filed a claim with the County on September 25, 2019. The County denied the claim and mailed notice of the denial on November 1, 2019. The notice warned that, subject to exceptions, the plaintiffs had six months from the date the notice was mailed or delivered to file a court action.

The plaintiffs filed suit in California Superior Court on June 4, 2020. The County removed the case to federal court and moved to dismiss all three claims. The court granted the County’s request to take judicial notice of the County’s claim-rejection letter as a public record.

State-Law Claims

The court held that the two state-law claims were untimely under the California Government Claims Act. Before suing a public entity or employee for monetary damages, a claimant must first submit a claim to the governmental entity. After the entity mails written notice rejecting the claim, the claimant generally must sue within six months.

Because the County mailed its rejection notice on November 1, 2019, the six-month filing deadline was May 1, 2020. The court considered California court holidays designated during the coronavirus pandemic and concluded that the deadline extended to June 1, 2020. June 1 was the next non-holiday after the relevant period, because May 30 was a Saturday. The plaintiffs filed on June 4, 2020, so the court found the state-law claims untimely.

The court rejected the plaintiffs’ argument that the pandemic-related holidays tolled the limitations period by at least 59 days. It read the applicable California statutes as extending the period only when the last day for filing falls on a holiday, rather than adding every holiday occurring during the limitations period.

The court concluded that amendment could not cure the late filing. It therefore granted the County’s motion to dismiss the state-law claims with prejudice.

Federal Civil-Rights Claim

To state a claim under § 1983 against a government entity, the plaintiffs needed to allege a constitutional right, a County policy or custom, deliberate indifference to that right, and that the policy or custom was the force that caused the alleged violation. Deliberate indifference requires more than negligence; it requires facts showing a culpable state of mind and disregard of a known, serious risk.

The court found that the plaintiffs’ allegation that the County “knew or should have known” Harris was unfit for release described, at most, negligence. The complaint’s assertions that the County acted with deliberate indifference were legal conclusions unsupported by specific facts. The complaint also did not identify any County policy or custom, allege that such a policy or custom amounted to deliberate indifference, or allege that it caused the claimed constitutional violation.

The court noted that the complaint was unclear about whether the § 1983 claim was brought against only the County or also against the unidentified individual defendants. It stated that, even if the individuals were defendants on that claim, the complaint did not allege facts showing their personal participation in the alleged rights violation.

The court therefore granted the County’s motion to dismiss the § 1983 claim. It was not certain that amendment would be futile, and the plaintiffs had not previously had an opportunity to amend. The court accordingly granted leave to amend that claim.

Disposition

Judge Lucy H. Koh granted the County’s motion to dismiss the plaintiffs’ state-law claims with prejudice and granted the County’s motion to dismiss the § 1983 claim with leave to amend. The plaintiffs were ordered to file any amended complaint within 30 days. They could not add new causes of action or parties without a stipulation or court permission and had to attach a redlined comparison of the original and amended complaints. The order stated that failure to amend, or failure to correct the identified deficiencies, would result in dismissal of the deficient claim with prejudice.