Gonzalez v. Ahern

Background

Current and former inmates at Santa Rita Jail brought a putative class action under Section 1983, a federal civil-rights law that allows claims for constitutional violations by state or local actors. They alleged unconstitutional conditions of confinement involving inadequate or contaminated food, inadequate sanitation, inadequate medical care, enforced idleness, and First Amendment retaliation.

The defendants seeking dismissal included Alameda County, the Alameda County Sheriff’s Office, two individual sheriff’s deputies, Wellpath Management, Inc., and Aramark Correctional Services LLC. Wellpath joined the County’s motion, while Aramark filed a separate motion. The motions challenged the Fourth Amended Complaint, including claims the court had previously found adequately pleaded.

Rulings

Food claims. The plaintiffs were no longer asserting that the food’s nutritional content was inadequate. They instead alleged chronic shortages and food that was inedible because of contamination or spoilage. The court denied Aramark’s and the County’s motions to dismiss these claims, relying on its earlier reasoning.

Sanitation claims. The court denied the County’s motion to dismiss the claims alleging insufficient and inadequate sanitation, again relying on its earlier reasoning.

Medical-care claims. The plaintiffs brought medical-care claims both against the County and Wellpath under a policy-or-practice theory known as a Monell claim, and against Deputies Joe and Ignot in their individual capacities. The court granted the motion to dismiss the claims against Joe and Ignot because the allegations did not show a pattern or practice of deliberate indifference by those deputies that entitled a named plaintiff or class member to relief.

The court denied the motion to dismiss the Monell claims against the County and Wellpath. It concluded that the amended allegations plausibly supported an inference that the contract and Wellpath’s cost-reduction practices created financial incentives to deny or delay needed medical care. The court cited allegations involving inhaler access, delayed treatment after a fall, refusal to provide an eye examination, delayed evaluation for cervical cancer, and difficulty obtaining dental care.

First Amendment retaliation. The court had previously allowed Daniel Gerrans’s claim to proceed based on an alleged transfer in retaliation for filing a grievance and the transfer’s alleged chilling effect on his First Amendment rights. The court granted the motion to dismiss the retaliation claim as to the class. It denied the motion as to Gerrans, except for his claim against Captain Hesselein, which the plaintiffs had abandoned and which the court dismissed.

Disposition

The court granted in part and denied in part the defendants’ motions to dismiss. The surviving claims were the inadequate and unsanitary food claims, the inadequate medical-care claims against the County and Wellpath, the inadequate-sanitation claims, and Gerrans’s First Amendment retaliation claim. The court dismissed the claims for relief against Deputies Joe, Ignot, and Captain Hesselein, as well as the First Amendment retaliation claim as to the class, without leave to amend because further amendment would be futile. Defendants’ answers were due within 21 days, and the court scheduled an initial case-management conference.