Crosby v. County of Alameda

Background

The case arose from Christopher Crosby’s death on December 4, 2019, while he was incarcerated at Santa Rita Jail in Alameda County. The opinion states that plaintiff Kathy Crosby was his mother and plaintiff C.C. was his daughter. Plaintiffs alleged that Christopher Crosby had been admitted to the jail in February 2018 and classified as a suicide risk by County correctional officers and Wellpath staff. Wellpath provided medical services for inmates at the jail.

According to the First Amended Complaint, County and Wellpath personnel failed to monitor Christopher Crosby properly and failed to prevent him from possessing a plastic bag, which he allegedly placed over his head, causing him to suffocate and die.

Claims and Motion

Plaintiffs asserted two federal claims against Wellpath and two groups of unidentified defendants. The claims alleged violations of Christopher Crosby’s substantive due-process rights and plaintiffs’ right to a family relationship under 42 U.S.C. § 1983, a federal civil-rights statute. Plaintiffs also asserted a state-law wrongful-death negligence claim against Wellpath and the unidentified Wellpath employees.

The County moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. The County argued that any claims against it failed because plaintiffs had not alleged facts showing that a municipal policy caused a constitutional violation. Under the rule described in the opinion, a municipality generally cannot be held liable under § 1983 for an employee’s conduct unless the alleged violation resulted from an official municipal policy.

The court noted that none of the causes of action in the First Amended Complaint was actually asserted against the County. Plaintiffs stated that they would seek leave to add claims against the County after discovery. The court nevertheless considered the County’s argument on the assumption that plaintiffs intended to assert the federal claims against it.

Ruling

The court concluded that the allegations still did not sufficiently connect any constitutional deprivation to a County policy. It therefore dismissed the claims against the County without further leave to amend. The court did not address the County’s additional arguments concerning the standards for deliberate indifference or conduct that shocks the conscience.

The County also argued in its reply that the federal claims against Does 1–25, alleged County employees, should be dismissed. The court declined to consider that request because the County’s motion had sought dismissal of claims against the County, not the unidentified defendants, and the County raised the Doe-defendant argument for the first time in its reply. The court therefore denied the motion without prejudice as to claims against Does 1–25, allowing the County to file an appropriate motion on their behalf if warranted.

The order thus granted in part and denied in part the County’s motion to dismiss: it granted dismissal of the claims asserted against the County without further leave to amend, and denied dismissal of the claims against Does 1–25 without prejudice.