B.R., a minor v. County of Santa Clara

Background

B.R. asserted municipal-liability claims against the County and Garnette. The opinion says B.R. primarily pursued a failure-to-train theory. B.R. also argued that discrepancies between official incident reports written by staff and B.R.’s account of what staff had done reflected a policy or custom of failing to investigate incidents in which detainees were harmed by staff.

Court’s analysis

The court held that the record contained no evidence about the contents of the training received by staff at the facility. It also found no evidence about other similar incidents that allegedly were not investigated. In addition, the record did not support a conclusion that a final policymaker was involved in or ratified the incident.

The court said that plausible allegations in the complaint were not enough at the summary-judgment stage. The plaintiff had the obligation to present evidence supporting the municipal-liability allegations. The opinion states that, based on the hearing, plaintiff’s counsel apparently had not conducted discovery concerning the training or investigation theories.

Ruling

The court granted the motion for summary judgment as to the municipal-liability claims against the County and Garnette. It also granted the defendants’ unopposed motion for summary judgment on the Bane Act claim. The opinion does not state that either ruling was made with or without prejudice.