Eaves v. Alameda County Sheriff Department
- William Alsup
- 3:20-cv-06808
- U.S. District Court · Northern District of California
- 2
In Eaves v. Alameda County Sheriff Department, Judge Alsup dismissed Shelton Eaves’s civil-rights case after his amended complaint still failed to state a claim.
The dismissal ended Shelton Eaves’s claims against the Alameda County Sheriff Department and R. Slaughter in this case.
What happened
Eaves v. Alameda County Sheriff Department involved Shelton Eaves, an inmate who sued under a federal civil-rights law. He alleged that jail officials did not immediately clean blood from the floor after another inmate with COVID-19 fell there.
The court had allowed Eaves to amend his original complaint, but found that the amended complaint did not fix the problems. Eaves did not allege that he became sick or suffered a physical injury, did not provide evidence that COVID-19 could spread through blood in these circumstances, and challenged conduct that the court viewed as a reasonable response because officials relied on a professional cleanup service.
Judge Alsup dismissed the case, ordered the clerk to enter judgment, and closed the file.
The detailed version
- Eaves v. Alameda County Sheriff Department · No. 3:20-cv-06808
- William Alsup
- Jan. 21, 2021
Background
Shelton Eaves, an inmate in the Alameda County Jail, filed a complaint without a lawyer under 42 U.S.C. § 1983. He alleged that jail officials failed to immediately clean up after another inmate with COVID-19 fell and bled on the floor. The defendants were the Alameda County Sheriff Department and R. Slaughter.
The court had previously dismissed the original complaint with leave to amend. It explained that a pretrial detainee bringing a constitutional failure-to-protect claim against an individual officer must show that the officer intentionally made a decision about the conditions of confinement; those conditions created a substantial risk of serious harm; the officer failed to take reasonable available measures despite an objectively high and obvious risk; and that failure caused the plaintiff’s injuries.
Reasons for Dismissal
The amended complaint did not allege a cognizable injury. Eaves did not allege that he became sick or contracted COVID-19. The court noted that the incident occurred on July 17, 2020, while Eaves prepared the amended complaint on December 17, 2020, and concluded that he would have become ill before then if he had contracted an illness from the incident. The court also stated that Eaves could not obtain money damages based only on fear without showing a physical injury, citing 42 U.S.C. § 1997e(e).
The amended complaint also did not allege or cite evidence that COVID-19 could be transmitted through blood, particularly to someone who did not come into contact with the blood. In addition, the allegations showed that jail officials relied on a professional hazardous-materials cleanup service, which the court found was a reasonable response to a potential health threat. The court concluded that the allegations did not establish deliberate indifference, an unconstitutionally unsafe condition, or a cognizable injury.
Disposition
Judge William Alsup held that the amended complaint failed to state a cognizable claim for relief. The case was dismissed. The clerk was ordered to enter judgment and close the file.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.