Williams v. County Of Monterey

Background

The court previously issued an order granting in part and denying in part defendants’ motions for summary judgment. That order granted summary judgment on Claim 6 and limited plaintiffs’ claims against the County under the rule commonly associated with Monell to failure-to-train theories. Plaintiffs moved for reconsideration, asking the court to reinstate Claim 6 against County Defendants Linda Castillo, Justin Ricks, and Chelsea Chacon and to allow their County claims to proceed on both inadequate training and a practice or custom of unlawful warrantless removal of children.

Defendants separately filed an administrative motion seeking permission to brief whether the court could reconsider its earlier order on its own authority. The court found that plaintiffs had not met the requirements of Civil Local Rule 7-9(b), because they had not identified a material change in facts or law, new material facts or law, or a manifest failure to consider previously presented material. The court nevertheless concluded that it had inherent authority to correct its own order before judgment and that defendants had received a fair opportunity to address the substantive issues through briefing and oral argument.

Claim 6

Claim 6 alleges that defendants violated the plaintiffs’ Fourteenth Amendment rights to familial association and the minor plaintiffs’ Fourth Amendment rights by submitting materially false or incomplete information to the Juvenile Dependency Court, contributing to the children’s continued separation from their family.

The court reconsidered its earlier understanding of the claim against Castillo and Ricks. Plaintiffs’ clarified theory was that Castillo and Ricks included material misstatements or omissions in delivered service logs, knowing those logs would be used to prepare the petition submitted to the Juvenile Dependency Court. The court held that plaintiffs could establish liability by showing a misrepresentation or omission made deliberately or with reckless disregard for the truth, incorporated into the petition, and material to the court’s detention decision.

The court found evidence from which a reasonable jury could conclude that Castillo’s report about what Q.S. wrote and Ricks’s descriptions of Monia Williams’s conduct were materially misleading and were incorporated into the petition. The court also found that a reasonable jury could conclude that Chacon’s omission from the petition of information about Castillo’s inability to qualify the children was material to the detention decision. The court rejected, however, plaintiffs’ separate argument that Chacon’s signing the petition without personal knowledge, by itself, established reckless disregard for the truth.

The court therefore granted reconsideration as to Claim 6 and reinstated that claim against Castillo, Ricks, and Chacon. The court stated that plaintiffs were not limited at trial to the specific examples discussed, but warned that alleged misstatements or omissions in the service logs must also have been reflected in the petition and material to the detention decision.

County Claims

The court also reconsidered the scope of plaintiffs’ claims against the County. Although the summary-judgment hearing transcript showed that plaintiffs’ counsel agreed that the claims were limited to inadequate training, the court concluded that its earlier order had treated the inadequate-training claims as encompassing evidence concerning a practice or custom of warrantless removal.

After reviewing the record and relevant law, the court concluded that inadequate-training claims and practice-or-custom claims were closely linked but distinct. It found that plaintiffs had presented sufficient evidence to proceed to trial on both theories: inadequate training in obtaining warrants to remove minors and a practice or custom of unlawful warrantless removal of minors.

Evidentiary Rulings and Disposition

Plaintiffs also sought reconsideration of evidentiary rulings excluding declarations about child-welfare investigations involving other families. The court declined to revisit those rulings, explaining that plaintiffs had prevailed on the scope of the County claims and that the exclusion of the declarations at the summary-judgment stage did not determine their admissibility at trial.

The court denied defendants’ administrative motion. It granted plaintiffs’ motion for reconsideration as to Claim 6 and the scope of the County claims, while leaving the evidentiary rulings unchanged. The order did not determine that any defendant was ultimately liable; it held that the specified claims could proceed based on evidence sufficient to create genuine disputes for trial.