Smith v. Office of the Alameda County Public Defender

Background

Reginald Smith alleged that he was detained at Coalinga State Hospital for 12 years without access to a jury trial in proceedings under California’s Sexually Violent Predator Act. He claimed that the delay violated his Fourteenth Amendment right to due process. Smith was represented by an Alameda County public defender from 2008 to 2009 and then by attorneys from the Alameda County Bar Association’s Court Appointed Attorneys Program.

In 2019, the Alameda County Superior Court granted Smith’s request for release based on a California decision involving delay in sexually violent predator proceedings. The federal court said that Smith had not argued that the state court decision should have preclusive effect, so it considered only evidence properly in the federal case record.

Smith and the defendants filed cross-motions for summary judgment. Smith sought judgment on his claims that his right to a speedy trial was violated and that the County’s failure to supervise its public-defense system caused that violation. Defendants argued that the evidence did not establish a constitutional violation or municipal liability and that Diane Bellas and Brendan Woods were entitled to qualified immunity.

Speedy-trial due-process claim

The court explained that no binding precedent establishes a due-process right to a speedy civil-commitment trial in sexually violent predator proceedings. It nevertheless applied the four-factor balancing framework commonly used for speedy-trial claims: the length of the delay, the reasons for the delay, whether the person asserted the right, and prejudice.

The court denied Smith’s motion for summary judgment because genuine disputes of material fact remained. The evidence conflicted about whether and when Smith asserted or waived his right to a speedy trial and about the reasons for the delays. Because those facts were material to the balancing analysis, the court held that a factfinder had to resolve them.

County liability

The court also denied defendants’ motion for summary judgment on Smith’s claim against the County under Monell v. Department of Social Services. A municipality may be liable under this theory when a municipal policy, including a failure to supervise or oversee, reflects deliberate indifference to a constitutional right and is the moving force behind the violation.

The court found enough evidence for a jury to determine whether the County failed to provide supervision, reporting, or oversight for attorneys representing accused sexually violent predators. The record indicated that those attorneys had no assigned supervisors, their work and case files were not reviewed, their time and resources were not monitored, and the County did not receive information about the progress of these cases. The court said a jury could find that this lack of oversight caused the alleged constitutional violation. It therefore denied defendants’ motion on the Monell claim.

Qualified immunity

Qualified immunity generally protects government officials from damages liability unless they violated a constitutional or statutory right that was clearly established at the time. The court concluded that Bellas and Woods were entitled to qualified immunity. Although Smith relied on decisions discussing speedy-trial rights, the Supreme Court and the Ninth Circuit had not addressed a speedy-trial right in sexually violent predator proceedings, and Smith did not identify a case making it obvious that Bellas’s or Woods’s lack of supervision would violate that right.

Disposition

The court granted defendants’ request for judicial notice of specified state-court records. It denied Smith’s motion for summary judgment. It granted in part and denied in part defendants’ motion for summary judgment: it granted the motion as to Smith’s claims against Bellas and Woods, who were entitled to qualified immunity, and denied it in all other respects.