Cravotta v. County of Sacramento

Summary

The United States District Court for the Eastern District of California addresses three motions to dismiss claims arising from the alleged assault of a former pretrial detainee by his cellmate. The court dismisses in part claims under the Fourteenth Amendment, the Rehabilitation Act, the Americans with Disabilities Act, California Government Code section 845.6, and related state-law theories, generally with leave to amend. The order concerns alleged deliberate indifference, failure to protect, failure to summon medical care, disability discrimination, and related liability of county and medical-service defendants.

Holdings

1. The complaint did not plausibly allege deliberate indifference by Garces-Barrella, Oran, DeCarlo, or Turner because it did not show that their decisions exposed Cravotta to a substantial risk of serious harm or that Turner could reasonably have appreciated a specific threat from the cellmate.
2. The complaint failed to state Rehabilitation Act or ADA claims against the Regents because it did not allege that mental-health care was denied because of disability or that the alleged treatment amounted to a discriminatory refusal to accommodate.
3. The complaint failed to state section 845.6 claims against the individual Regent defendants or the Regents because it did not allege that they knew or had reason to know that Cravotta required immediate medical care and failed to summon it.
4. The Bane Act claims against the Regent defendants were dismissed because the complaint failed to plead the underlying deliberate-indifference, ADA, Rehabilitation Act, or section 845.6 violations. The Bane Act claims against the County defendants and Saesee were not dismissed to the extent they were adequately supported by surviving deliberate-indifference allegations or unchallenged regulatory theories.
5. The negligence claims were sufficiently pleaded against defendants for whom deliberate-indifference allegations survived, including Rollon, Whiting, Blevins, Singh, Haynes, Higley, and Saesee, but were dismissed against Sturgis, Albright-Mundy, McLean, Paredes, Noda, and the Regents on the allegations presented.
6. Cravotta had standing to challenge Saesee's classification of Burleson because the complaint alleged a non-attenuated line of causation between the classification decision, Burleson's placement in general population, the cell assignment, and the assault.
7. The complaint plausibly alleged deliberate-indifference claims against Rollon, Whiting, Blevins, Singh, Haynes, Higley, and Saesee, but not against Sturgis, Albright-Mundy, Paredes, McLean, or Noda.

Questions Presented

1. Whether the Third Amended Complaint plausibly alleged Fourteenth Amendment deliberate-indifference claims against the various mental-health, classification, housing, monitoring, and medical-response defendants.
2. Whether Cravotta had Article III standing to challenge Defendant Saesee's classification of Burleson as causally connected to the later assault.
3. Whether the complaint stated claims under the Rehabilitation Act and ADA based on allegedly inadequate mental-health care and failure to accommodate.
4. Whether the complaint stated claims under California Government Code section 845.6 for failure to summon immediate medical care.
5. Whether the complaint stated claims under the California Bane Act.
6. Whether the complaint stated negligence claims against the defendants.

Disposition

other