Pearson v. State of California

Background

The case arose from events at Salinas Valley State Prison on June 18, 2018. Officers Williams and Hernandez found Gaines holding Pearson in a headlock. After Gaines refused orders to release Pearson, Williams used pepper spray, which struck both men and caused Gaines to release Pearson.

The officers then tried to handcuff Pearson so he could receive medical evaluation. When Pearson left his cell, the opinion states that he moved his shoulder toward Officer Aragon, flailed his arms, broke free of Williams’s grasp, and moved toward Aragon. Aragon took Pearson to the ground. Pearson pulled his arms under his chest, moved from side to side, and kicked his legs while officers attempted to handcuff him. The officers stated that Pearson was still breathing after being handcuffed. Pearson later became unresponsive and stopped breathing. Medical staff performed cardiopulmonary resuscitation, and Pearson was pronounced dead.

The parties disputed the cause of death. The Monterey County Medical Examiner concluded that Pearson died from acute methamphetamine intoxication after finding a ruptured plastic bindle in his stomach, methamphetamine and amphetamine in his blood, and coronary atherosclerosis. Plaintiffs’ experts instead attributed the death to restraint or positional asphyxia, chemical asphyxiation from pepper spray, or a combination of restraint and methamphetamine exposure. One plaintiffs’ expert stated that methamphetamine may also have contributed to the death.

Claims and Motions

The remaining claims against the officer defendants were claims under 42 U.S.C. § 1983 alleging violations of the Eighth and Fourteenth Amendments, along with state claims for battery, wrongful-death negligence, and violation of the Bane Act. The remaining claims against the supervisor defendants concerned alleged failure to train the officers about positional asphyxia. Defendants moved for summary judgment, and plaintiffs filed motions concerning their police-practices and forensic experts.

Qualified Immunity

Qualified immunity protects government officials from civil damages unless their conduct violated a constitutional or statutory right that was clearly established when the conduct occurred. Courts generally ask whether the official violated a constitutional right and whether the right was clearly established. The court did not decide whether the officers violated a constitutional right because it concluded that the plaintiffs had not shown the second requirement.

The court held that the plaintiffs had not identified controlling precedent making it clear that officers violated the Eighth or Fourteenth Amendments by using pepper spray in a confined cell to separate fighting cellmates or by applying pressure while handcuffing a resisting inmate in a face-down position. The court distinguished a prior case involving officers who continuously pressed on the neck and upper torso of a compliant, handcuffed person who said he could not breathe. The court stated that Pearson was resisting, did not comply with the officers’ commands, and did not indicate that he could not breathe during the handcuffing.

The court also stated that factual disputes about Pearson’s cause of death and whether officers dropped him were immaterial to the clearly established-law analysis, even when the facts were viewed favorably to plaintiffs.

Disposition

The court held that the officer defendants were entitled to qualified immunity and granted defendants’ motion for summary judgment on the Section 1983 claims. The conclusion states that plaintiffs’ federal claims were dismissed with prejudice. The court declined to exercise supplemental jurisdiction over the state-law claims and dismissed them without prejudice, stating that they could be pursued in the appropriate state court. The court also denied the pending motions in limine without prejudice. Judge Charles R. Breyer signed the order.