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 causes of action: general negligence, public-entity negligence, and a claim under 42 U.S.C. § 1983, a federal statute allowing claims for violations of constitutional or federal statutory rights by persons acting under state law.

The plaintiffs alleged that Harris, their 21-year-old son, was admitted to the Barbara Arons Pavilion of the Santa Clara Valley Medical Center on March 15, 2019, for acute psychiatric services. They alleged that he had been designated as gravely disabled and was ordered to remain at the medical center until March 29, 2019, but was released on March 26. They further alleged that he displayed similar behavior on the day of his release and, two days later, walked across Interstate 280 and was struck and killed by a vehicle.

The plaintiffs alleged that the County knew or should have known that 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 complaint, however, did not allege those facts.

Rulings on the County’s Requests

The court granted the County’s request for judicial notice of the County’s notice rejecting the plaintiffs’ claim. Judicial notice permits a court to consider certain facts from reliable public records without requiring ordinary proof of those facts. The court treated the claim-rejection notice as a public record and did not take judicial notice of facts subject to reasonable dispute.

State-Law Claims

The court dismissed the state-law claims for two independent reasons. First, California’s Government Claims Act requires a person seeking money damages from a public entity or employee to present a claim before filing suit. The complaint must allege compliance with that requirement or facts excusing compliance. Although the plaintiffs stated in their opposition that they had filed a claim and that the County had rejected it, the complaint did not allege those facts. The court therefore dismissed the state-law claims on this basis.

Second, the court held that California Government Code section 856 immunized the County from the state-law claims as pleaded. That statute protects a public entity and employees acting within the scope of employment from liability for injuries resulting from decisions about whether to release a person confined for mental illness or addiction. The court concluded that the plaintiffs’ state-law claims arose from the County’s alleged decision to release Harris prematurely. The court also rejected the plaintiffs’ argument that another statute created a duty to provide additional medical care, because that statute applies only to prisoners and the complaint did not allege that Harris was a prisoner.

The court also noted that California Government Code section 855.8 could provide immunity for injuries resulting from diagnosing or failing to diagnose mental illness or from failing to prescribe treatment, if the plaintiffs were claiming that misdiagnosis or inadequate medication caused the release. The court stated that section 856(c), concerning liability for certain acts or omissions by public employees, did not apply to the County as a public entity and that the complaint did not make specific allegations about acts or omissions by individual employees.

Section 1983 Claim

The court granted the County’s motion to dismiss the section 1983 claim. To state a claim against a local government, the plaintiffs had to plausibly allege a constitutional right, a County policy or custom, deliberate indifference to that right, and that the policy or custom was the moving force behind the violation. “Deliberate indifference” requires more than negligence; it requires facts showing that the government recognized an unreasonable risk and intentionally exposed the plaintiff to it without regard to the consequences.

The court found that the plaintiffs’ allegations that the County knew or should have known Harris was unfit for release described, at most, negligence. Their 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 added that, if the section 1983 claim was intended to name the unknown individual defendants, the complaint also failed to allege their personal participation.

Disposition

The court granted the County’s motion to dismiss with leave to amend. The plaintiffs had 30 days to file an amended complaint. The order stated that failure to amend, or failure to correct the deficiencies identified in the order or motion, would result in dismissal of the deficient claims with prejudice. The plaintiffs could not add new causes of action or new parties without a stipulation or the court’s permission.