Castro v. County of Los Angeles

The County of Los Angeles (the county) (defendant) arrested Jonathan Castro (plaintiff) on a misdemeanor charge for public drunkenness. At the station, Castro was placed in a dedicated sobering cell. A few hours later, the county arrested Jonathan Gonzalez on a felony charge for punching a glass door at a nightclub. Officers described Gonzalez as acting erratically and combatively during intake. Officers then placed Gonzalez in the sobering cell with Castro. The station supervisor (defendant) assigned an unpaid community volunteer to monitor the sobering cell. A few minutes after Gonzalez was placed with Castro, Castro pounded on the cell’s door and window, trying to get an officer’s attention. However, no one responded. Twenty minutes later, the volunteer looked into the sobering cell. The volunteer saw what he thought was Castro sleeping and Gonzalez touching Castro’s thigh inappropriately. The volunteer reported the observation to the station supervisor. Six minutes later, the supervisor entered the sobering cell and discovered Gonzalez stomping on Castro’s head. Castro suffered severe cognitive injuries that required long-term medical care. Castro sued the county, the station supervisor, and another supervisor (defendant) in federal district court, alleging that they violated his Fourteenth Amendment due-process rights by confining him in a dangerous environment that injured him. A jury found for Castro and awarded him $2 million. The county and the supervisors appealed to the United States Court of Appeals for the Ninth Circuit, which agreed to hear the case en banc.