Gonzalez v. Ahern

Background

Plaintiffs, described as current and former inmates from Santa Rita Jail, brought a proposed class action under 42 U.S.C. § 1983, a federal law allowing claims against state or local actors for constitutional violations. They alleged unconstitutional conditions of confinement involving inadequate and unsanitary food, inadequate medical care, and inadequate sanitation. The defendants were Alameda County, the Alameda County Sheriff’s Office, four individual deputies, Wellpath Management, Inc., and Aramark Correctional Services LLC.

The court had previously allowed plaintiffs to file a fifth amended complaint to substitute new named plaintiffs for plaintiffs who were no longer detained at Santa Rita Jail. The court stated that plaintiffs had not been granted permission to add defendants or new theories of liability. Plaintiffs nevertheless filed a complaint that added defendants and pleaded claims beyond the categories the court had identified.

Aramark’s Motion

Aramark argued that several newly added plaintiffs, as well as plaintiffs Lockhart and Harris, lacked Article III standing to pursue food claims because the complaint did not describe food served to them. The court explained that standing requires an injury that is concrete and particularized, caused by the defendant, and likely to be remedied by a court order. Although the complaint did not include individual food allegations for those plaintiffs, it alleged that all detainees received food from the same kitchen and that the kitchen had rodents, birds, animal droppings, contaminated food, foreign objects, and spoiled or inedible food. The court held that these allegations plausibly showed a substantial risk of serious injury and were sufficient to establish standing.

Aramark also argued that the complaint did not adequately allege a company policy or widespread practice supporting liability under Monell, the doctrine governing when a local government or similar entity may be liable for an unconstitutional policy or custom. The court rejected that argument, relying on its earlier rulings and finding that plaintiffs adequately alleged a practice of serving contaminated, spoiled, and otherwise inedible food. The court also held that plaintiffs adequately alleged that Aramark was deliberately indifferent to their health and safety because the food conditions placed them at substantial risk of harm and Aramark’s conduct was objectively unreasonable.

The court noted that plaintiffs were not pursuing a claim based merely on the adequacy of their diet. Their food claims were based on contamination, spoilage, and inedibility. Aramark’s motion to dismiss was DENIED.

The County’s Motion

The County’s motion to dismiss the claims against newly added defendants Deputy Lenahan and Classification Sergeant MacBride was GRANTED because plaintiffs had not sought, and the court had not granted, permission to add them. The court also dismissed the repleaded class-wide First Amendment claim because it had previously been dismissed without leave to amend. The court stated that plaintiffs conceded that the previously dismissed individual inadequate-medical-care claims against Deputies Joe and Ignot should be dismissed.

The County also moved to dismiss the claims of the new named plaintiffs for failure to state a claim. The court DENIED that motion as to Eric Wayne, James Mallett, Rasheed Tucker, Darryl Geyer, and Timothy Phillips. The court found that their allegations, viewed in the plaintiffs’ favor, adequately stated claims based on inadequate medical care and related conditions.

The court GRANTED the motion as to Tiara Arnold. Arnold alleged that she did not receive a pillow, extra mattress, and shoes after returning to Santa Rita Jail, despite previously receiving authorization for those items. The court found that she did not allege that the items were medically necessary or that Wellpath withheld them to reduce costs. The court also stated that the allegations did not fit plaintiffs’ stated theory of liability and that plaintiffs had not received permission to add a new claim.

Wellpath’s Joinder

Wellpath filed a late paper joining the County’s motion to dismiss. Because Wellpath filed it three days after the court-ordered deadline and did not seek permission to file late, the court stated that it would not consider the submission.

Disposition

The court ordered that the defendants’ motions to dismiss were GRANTED IN PART and DENIED IN PART. The surviving claims were: inadequate and unsanitary food claims against the County and Aramark; inadequate-medical-care claims against the County and Wellpath; inadequate-sanitation claims against the County and Plaintiff Gerrans’ individual claim against Deputies Joe and Ignot; and Plaintiff Gerrans’ First Amendment claim against the County. The claims against Deputy Lenahan and Classification Sergeant MacBride, the inadequate-medical-care claims against Deputies Joe and Ignot, and Tiara Arnold’s claims were dismissed. The court directed defendants to answer by November 21, 2022, and set a case-management conference to discuss a schedule for class-certification briefing. Judge Jacqueline Scott Corley signed the order.