Pearson v. State of California
- Charles Breyer
- 3:20-cv-05726
- U.S. District Court · Northern District of California
- 7
Pearson v. State of California: Judge Breyer partly denied and partly granted defendants’ dismissal motion over claims arising from Pearson’s death in prison custody.
The order affects four of Coltrane Pearson’s children, the named correctional officers and supervisors, and the State of California. The surviving theories include claims against the officers and limited federal and state claims against the supervisors concerning failure to train about positional asphyxia; the other claims cannot be amended further.
What happened
In Pearson v. State of California, four of Coltrane Pearson’s children sued correctional officers, supervisors, and California after Pearson died following an altercation and use of force at Salinas Valley State Prison. They brought federal civil-rights claims and state-law claims.
The court allowed the case to continue on previously accepted claims against the officers, including excessive force, interference with family relationships, wrongful death, and the Bane Act. It also allowed claims against the supervisors based on allegedly failing to train officers about positional asphyxia, but rejected the other newly amended claims.
Judge Breyer partly denied and partly granted the motion to dismiss. He denied it for the specified claims and granted it for all other claims, while denying leave to amend because further amendment would be futile.
The detailed version
- Pearson v. State of California · No. 3:20-cv-05726
- Charles Breyer
- Apr. 26, 2022
Background
Coltrane Pearson, an inmate at Salinas Valley State Prison, died on June 18, 2018, after correctional officers intervened in an altercation between inmates. According to the third amended complaint, officers used pepper spray, forced Pearson into a prone position, applied pressure and weight to his body, restrained him, and dropped him to the ground. Pearson became unresponsive at 4:35 p.m., received medical treatment or lifesaving measures at 4:38 p.m., and died at 5:08 p.m. The plaintiffs alleged that an autopsy found multiple blunt-force injuries and that the injuries were consistent with restraint asphyxia caused by excessive force and restraints.
Four of Pearson’s children—N.P., Coltrane Jr., K.P., and Akaysia—brought claims individually and as successors-in-interest. The defendants included seven correctional officers, three supervisors, and the State of California. The plaintiffs asserted federal civil-rights claims under 42 U.S.C. § 1983 and state-law claims.
Claims Previously Allowed to Proceed
The court said it would not revisit its earlier rulings allowing certain claims against the Officer Defendants to proceed. Those claims were Section 1983 claims for excessive force and deprivation of a familial relationship, and state-law claims for wrongful death and under the Bane Act. In the conclusion, the court denied the motion to dismiss as to Claims 1, 4, 7, 8, and 9 against the Officer Defendants.
Failure-to-Protect Claim
The court dismissed Claim 2, which alleged that defendants failed to protect Pearson from his cellmate. The court found the claim insufficiently pleaded because the complaint did not provide new facts showing that defendants knew of an excessive risk posed by the cellmate. Because the court had already dismissed the claim for the same reason, it denied leave to amend.
Medical-Care Claims
The court dismissed Claims 3 and 10, which alleged deliberate indifference to Pearson’s serious medical needs under Section 1983 and California Government Code section 845.6. The court relied on its earlier conclusion that the three-minute period between Pearson’s becoming unresponsive and the start of treatment did not plausibly suggest deliberate indifference. The amended complaint still did not allege specific facts showing that Pearson’s serious medical needs were clear to a defendant before 4:35 p.m., or that a defendant delayed or denied care after that time. The court denied leave to amend.
Claims Against the Supervisor Defendants
The court denied the motion to dismiss Claim 5, a Section 1983 claim, and Claim 9, a state negligence claim, against the Supervisor Defendants only to the extent they were based on allegedly failing to train the Officer Defendants about positional or restraint asphyxia and the risks of restraining someone prone with weight on the person’s back. The court found that the amended allegations sufficiently pleaded culpable action or inaction in training, supervision, or control that led to Pearson’s injury, although the allegations remained somewhat vague.
The court dismissed Claim 6, the Section 1983 claim based on alleged unconstitutional customs and policies, because the allegations remained too vague. It also dismissed the other claims against the Supervisor Defendants without leave to amend. The court explained that individual public employees could not be held vicariously liable under California law but could be liable for their own negligent acts; on that basis, it permitted the negligence theory concerning failure to train about positional asphyxia.
Other Rulings and Disposition
The court agreed with defendants that punitive damages were unavailable under the circumstances described, that plaintiffs could not sue defendants in their official capacities, and that wrongful-death damages were unavailable for Section 1983 claims.
The court denied the motion to dismiss as to Claims 1, 4, 7, 8, and 9 against the Officer Defendants, and as to Claims 5 and 9 against the Supervisor Defendants only on the positional-asphyxia failure-to-train theory. It granted the motion as to all other claims and denied leave to amend because amendment would be futile. Judge Charles R. Breyer signed the order on April 26, 2022.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.