Mohrbacher v. Alameda County Sheriffs Office
- James Donato
- 3:18-cv-00050
- U.S. District Court · Northern District of California
- 7
In Mohrbacher v. Alameda County Sheriffs Office, Judge Donato denied class certification for pregnant-inmate medical-care claims, leaving the named plaintiffs’ individual claims.
The named plaintiffs’ individual claims remain in the case, but the proposed classes of women who were pregnant while incarcerated at Santa Rita Jail were not certified. CFMG remains the sole remaining defendant identified in the opinion.
What happened
In Mohrbacher v. Alameda County Sheriffs Office, plaintiffs sought to represent current and future women who were pregnant while incarcerated at Santa Rita Jail. The only remaining defendant was California Forensic Medical Group, which provided jail medical services under contract with the Alameda County Sheriff’s Office.
The court found that plaintiffs had not shown their pregnancy-related problems resulted from common policies or practices. Instead, the evidence described individual medical experiences involving a small number of inmates and did not establish that those experiences were typical across the proposed class.
Judge Donato denied certification under both parts of Federal Rule of Civil Procedure 23 that plaintiffs proposed to use. The case will continue on behalf of the named plaintiffs individually, and the parties were directed to propose a pretrial and trial schedule.
The detailed version
- Mohrbacher v. Alameda County Sheriffs Office · No. 3:18-cv-00050
- James Donato
- Mar. 22, 2024
Background
The named plaintiffs alleged claims concerning the treatment of women incarcerated at Santa Rita Jail, including claims about medical care for pregnant inmates. The Alameda County Sheriff’s Office and Aramark Correctional Services, LLC, settled the claims directed against them before trial. The remaining defendant was California Forensic Medical Group (CFMG), which provided jail medical services under contract with the Sheriff’s Office.
Plaintiffs sought certification of a class consisting of all current and future females who had been pregnant while incarcerated at Santa Rita Jail since January 2017. They primarily sought certification under Federal Rule of Civil Procedure 23(b)(2), which concerns classes seeking common injunctive or declaratory relief. Plaintiffs also mentioned damages classes under Rule 23(b)(3), which requires common questions to outweigh individual ones, although the court found that discussion underdeveloped.
Court’s analysis
The court focused on commonality and typicality under Rule 23(a). Commonality requires proof that the case presents questions capable of producing answers that resolve important issues for the class as a whole. Typicality requires the representative plaintiffs’ claims to be typical of the class members’ claims.
The court found that plaintiffs had not shown that the pregnancy complications they described resulted from CFMG policies or systemic practices. The named plaintiffs’ allegations involved different, pregnancy-specific experiences. Zepeda alleged that CFMG overlooked signs of a miscarriage before she received medical attention at a local hospital. Mohrbacher alleged inadequate care during a high-risk pregnancy, weight gain connected to the diet provided in custody, unsuitable shoes, and inadequate access to a bathroom. Ibe alleged that a low-fiber diet caused hemorrhoids during her pregnancy.
The court also found that plaintiffs offered evidence about only a small number of women, despite stating that approximately 600 pregnant women were housed at Santa Rita Jail between 2017 and 2022. Plaintiffs did not connect that evidence to a common policy or practice affecting pregnant inmates. The court distinguished a case in which class certification was supported by extensive discovery materials, expert reports, declarations, and evidence of specific policies and practices affecting the proposed class.
The court concluded that describing a handful of individual incidents did not establish common questions or show that the named plaintiffs’ experiences were typical of the class. It also concluded that plaintiffs had not shown that class members sought uniform relief from a generally applicable practice for purposes of Rule 23(b)(2), or that common questions predominated over individual questions for purposes of Rule 23(b)(3).
Disposition
The court denied certification of all proposed classes. The case will proceed on behalf of the named plaintiffs individually. The parties were directed to jointly file by April 18, 2024, a proposed pretrial and trial schedule based on a November 2024 trial date.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.