Richardson v. California Department of Corrections and Rehabilitation

Background

Adron Adams, Jr. was incarcerated at Salinas Valley State Prison, which the opinion says is overseen by the California Department of Corrections and Rehabilitation. Plaintiffs Sheila Richardson and Adron Adams, Sr. filed the action as successors in interest after Adams died by suicide on January 30, 2021. They alleged that correctional staff, supervisors, guards, and medical professionals knew about Adams’s mental-health conditions, self-harm symptoms, and suicidal thoughts but did not prevent his death.

The complaint asserted four causes of action: two civil-rights claims under 42 U.S.C. § 1983 against correctional employees identified as Does 1-6; a claim based on an unconstitutional government policy or practice, commonly called a Monell claim, against the state entities and managerial employees identified as Does 7-10; and a wrongful-death claim against all defendants. Defendants moved to dismiss the entire complaint. The court also granted defendants’ request for judicial notice of the claim and rejection letters from the California Government Claims Program.

Claims Against Does 1-6

The first § 1983 claim alleged that Does 1-6 were deliberately indifferent to Adams’s serious mental-health needs, violating the Eighth Amendment. The court explained that deliberate indifference requires facts showing that officials knew of a substantial risk to the incarcerated person and lacked a reasonable justification for exposing him to that risk. The court held that the complaint relied on bare, conclusory statements and did not identify direct or circumstantial evidence showing that Does 1-6 knew about Adams’s conditions or symptoms on the day of his death. The court therefore granted dismissal of the medical-care claim with leave to amend.

The second § 1983 claim alleged that Does 1-6 violated the Fourteenth Amendment by depriving the plaintiffs of Adams’s companionship. The court said this type of claim requires conduct that shocks the conscience, which can be shown through deliberate indifference or a purpose to harm. Because the complaint did not adequately show deliberate indifference, the court granted dismissal of the familial-association claim with leave to amend.

Monell Claim

The plaintiffs alleged that the state entities and Does 7-10 failed to train employees in medical and mental-health care, including suicide prevention. The court explained that a Monell claim applies to an unconstitutional policy or practice of a local government and is not the proper vehicle for claims against individual defendants. Because Does 7-10 were sued as individual supervisory employees, the court granted dismissal of the Monell claim against them without leave to amend, finding that amendment would be futile.

The court separately held that the Monell claim against the California Department of Corrections and Rehabilitation and Salinas Valley State Prison was barred by sovereign immunity under the Eleventh Amendment. The opinion states that both are state agencies and that the plaintiffs had not alleged a waiver of immunity. It also rejected the argument that California’s waiver of immunity for certain tort claims in state court waived federal-court immunity. The court granted dismissal of the Monell claim against the state entities with leave to amend, while cautioning that the plaintiffs would need to address waiver or abrogation of immunity.

Wrongful-Death Claim

The defendants argued that the wrongful-death claim against Does 1-10 was untimely under the California Government Claims Act. The plaintiffs’ claim was received by the California Government Claims Program on August 3, 2021, and rejected on December 29, 2021. The rejection letter warned that a court action had to be filed within six months. The plaintiffs filed this action on October 18, 2022, which the court found was more than three months after the deadline.

The court rejected the plaintiffs’ argument that they did not need to present a claim concerning public employees, explaining that presentation of a claim against the employing public entity was required. The court also found no support for the argument that some Doe defendants might be independent contractors. It dismissed the wrongful-death claim against Does 1-10 with leave to amend.

Punitive Damages and Disposition

Defendants moved to strike the punitive-damages claim, arguing that punitive damages could not be awarded against the state entities and were unavailable for wrongful-death claims. The plaintiffs responded that they were not seeking punitive damages on either of those theories. The court therefore denied the motion to strike the punitive-damages claim.

In summary, the court: (1) granted defendants’ motion to dismiss the wrongful-death, medical-care, and familial-association claims with leave to amend; (2) granted dismissal of the Monell claim against the state entities with leave to amend; (3) granted dismissal of the Monell claim against Does 7-10 without leave to amend; and (4) denied defendants’ motion to strike the punitive-damages claim. The plaintiffs could file an amended complaint by March 20, 2023, and could not add parties or claims without the court’s permission. If they did not file a plausible amended complaint, the court stated that it would enter judgment and close the case.