Miles v. Cnty. of Alameda
| Decision Date | 03 April 2023 |
| Docket Number | 22-cv-06707-WHO |
| Parties | CHRISTY MILES, Plaintiff, v. COUNTY OF ALAMEDA, et al., Defendants. |
| Court | U.S. District Court — Northern District of California |
ORDER GRANTING IN PART AND DENYING IN PART THE COUNTY DEFENDANTS' MOTION TO DISMISS THE FIRST AMENDED COMPLAINT RE: DKT. NO. 28
On November 15, 2021, Devin West was beaten and strangled to death by his cellmate, Emil Cochran, while he was incarcerated at Santa Rita Jail in Alameda County. West's mother, Christy Miles, brought ten constitutional and state law claims individually and as West's successor-in-interest against the County of Alameda (“County”), California Forensic Medical Group Inc. (“CFMG”), and ten County and CFMG employees based on their failure to protect West and the allegedly inadequate medical care that West received prior to his death. The County-related defendants moved to dismiss alleging that, among other issues, Miles lacks standing, the claims are legally and factually deficient, and defendants are protected by immunity.
Miles has shown that she has standing to serve as West's successor-in-interest. Although at least some of the claims against at least some of the County defendants survive, it is too soon to tell whether Miles has stated a claim against all of the County defendants: Miles's claims and the County defendants' arguments for dismissal require a more developed factual record. West is dead, Miles was not in custody with him, and she has not had an opportunity to do any discovery, including finding out the names of any of the Does. Some of the claims, especially with respect to the Classification Does, appear plausible. I will allow a period of discovery so that Miles may identify the Doe defendants and other key facts in an amended complaint by July 25, 2023. At that point, the defendants may renew their motion to dismiss.
The First Amended Complaint (“FAC”) makes the following allegations, largely on information and belief. I accept all well-pleaded allegations as true for purposes of the motion to dismiss. Devin West, who was African-American and 27 years old at the time of his death, suffered from several mental illnesses, including bipolar disorder schizophrenia, and depression. FAC [Dkt. No. 24] ¶ 16. On September 20, 2021, West was arrested for burglary and battery. Id. ¶ 17. At the time of his arrest, West was on probation for robbery. Id.
During the intake and classification process at Santa Rita Jail, members of the Alameda County Sheriff's Office and the California Forensic Medical Group reviewed West's file to assess his classification criteria. Id. ¶¶ 18, 37. West was medically evaluated; his inmate file indicated that he had “behavior disturbance, illness, and suicidal ideations.” Id. ¶ 18.[1] County employees responsible for classifying inmates (the “classification Does”) determined that West should be housed in an area designated for close observation for the severely mentally ill-Housing Unit 9. Id. ¶¶ 22, 38.
While in custody at Santa Rita Jail, West displayed obvious signs and symptoms of unstable behavior and mental illness. Id. ¶ 23. Such behavior included: speaking incoherently or illogically, using vulgar and offensive words with both inmates and custodial staff, unprovoked threatening of inmates and custodial staff, and proclivity to get into fights with cellmates, followed by begging for someone to call home for him. Id. At some point, West was placed on the Inmate Observation Log, which is a form of suicide watch. Id.
West was involved in at least three separate fights with cellmates while at Santa Rita Jail. Id. ¶ 28. Each fight was either provoked by the cellmate or by West because of his mental illness. Id. Although West's ongoing mental illnesses made him incapable of requesting assistance and care as he would if he were not suffering from a mental health crisis, West communicated to deputies that he did not want to be double-celled with another inmate. Id. ¶ 34. At some point, based on West's criminal history, mental health issues, and recent fights with cellmates, custodial staff recommended that West be housed by himself in a single cell. Id. Even though the classification defendants knew that there was space for West to be housed in a single cell, id. ¶ 32, the classification defendants overruled the recommendation and continued to house West in a double-cell with another inmate. Id. ¶ 36.
On November 14, 2021, although West had not requested to be housed with Cochran, the two of them were placed in the same cell in Housing Unit 9. Id. ¶ 38. Cochran also suffered from serious mental illness and had “a violent criminal history stemming back at least ten years.” Id. ¶ 37. Cochran had previously been arrested and/or convicted of battery, possession of a firearm and ammunition, and vandalism, and in April of 2022, a judge ruled that Cochran was mentally incompetent to stand trial for murder. Id. Within hours of being housed together, Cochran and West had a disagreement which escalated into a physical altercation. Id. ¶ 39. Cochran, who was more muscular than West, beat and strangled West while West screamed for help. Id. West died at approximately 1am on the morning on November 15, 2021, approximately three days before he was set to be released. Id. ¶¶ 39-40.
During the evening of November 14 and early morning hours of November 15, Santa Rita Jail staff failed to conduct timely protective cell checks and thus failed to discover and prevent the altercation between West and Cochran. Id. ¶¶ 44, 45. Correctional staff must conduct more frequent health and protection cell checks for inmates housed in the mental health housing unit, which includes Housing Unit 9. Id. ¶ 26. For inmates who have been placed on the Inmate Observation Log, correctional staff are required to conduct health and safety cell checks at least every fifteen minutes. Id. ¶ 26.[2] The deputy Does failed to timely summon medical assistance for West after finding him beaten in his cell. Id. ¶ 47.
When Miles called the Santa Rita Jail to check on her son after he was supposed to be released, jail officials told her that West had already been released. Id. ¶ 41.
The Santa Rita Jail, which is considered a “mega jail,” can hold up to approximately 4,000 inmates and is one of the largest correctional facilities in California. Id. ¶ 32. Between 2017 and 2021, approximately 2,400 inmates on average were housed at the jail. Id. Approximately 40% of the inmates housed at Santa Rita Jail have “mental health concerns” and approximately 20-25% have “serious mental illness.” Id.
In 2017, the United States Department of Justice (“DOJ”) launched an investigation into Alameda County and Santa Rita Jail based on a “pattern and practice of constitutional violations in the conditions at the Santa Rita Jail . . . in its provision of public mental health services.” Id. ¶ 156(a). In April of 2021, approximately seven months before West's death, the DOJ concluded that there was reasonable cause to believe that the County provided constitutionally inadequate housing and care for its inmates with mental health needs, in violation of the Eighth Amendment. Id. The DOJ also found that there was reasonable cause to believe that Santa Rita Jail violates the Americans with Disabilities Act (“ADA”) by denying prisoners with mental health disabilities access to services, programs, and activities because of their disabilities. Id. From 2015 to 2019, at least 14 prisoners died by suicide at Santa Rita Jail. Id. In total, since 2014, fifty-eight people have died at Santa Rita Jail. Id. ¶ 156(d).
On or around May 10, 2022, West's mother, Christy Miles, served her “comprehensive claim against the County of Alameda pursuant to the applicable Government Code.” Id. ¶ 50. The County never responded to the claim. Id. ¶ 51.
On October 31, 2022, Miles filed suit against the County of Alameda, Wellpath Management, Inc., and Does 1 through 10, bringing ten claims under federal and state law arising from her son's death. See generally Complaint [Dkt. 1]. After learning that CFMG was the proper employer of the individual medical personnel at Santa Rita Jail, Miles amended her complaint to name CFMG instead of Wellpath. See FAC. The FAC, which is the operative pleading, includes the same ten claims: (1) “interference with familial relationship, due process -violation of the Fourteenth Amendment,” see id. ¶¶ 55-65; (2) “failure to protect - violation of the Eighth Amendment,” see id. ¶¶ 66-79; (3) denial of medical care under 43 [sic] U.S.C. § 1983, see id. ¶¶ 80-111; (4) supervisor liability under 42 U.S.C. § 1983, see id. ¶¶ 112-25; (5) municipal liability - failure to train under 42 U.S.C. § 1983, see id. ¶¶ 126-37; (6) municipal liability -ratification under 42 U.S.C. § 1983, see id. ¶¶ 138-46; (7) municipal liability - unconstitutional custom, practice, policy under 42 U.S.C. § 1983, see id. ¶¶ 147-61; (8) Americans with Disabilities Act - reasonable accommodation, see id. ¶¶ 162-85; (9) negligence, see id. ¶¶ 18694; and (10) violation of the Bane Act, see id. ¶¶ 195-203.
The FAC names four categories of County and CFMG employees as Doe defendants based on their roles at Santa Rita Jail. Does 1-2 are the “Classification Does,” who were responsible for “reviewing and obtaining all pertinent information for the proper classification of inmates including where an inmate will be housed, under what security level the inmate will be designated, and with whom an inmate will be housed with if any,” among other duties. id. ¶ 8. Miles alleges that the Classification Does “made the intentional decision regarding the conditions of confinement including the access to adequate medical care to Decedent...
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