Valenzuela v. City of Anaheim
United States Court of Appeals for the Ninth Circuit
6 F.4th 1098 (2021)
- Written by Eric Miller, JD
Facts
Anaheim police officers Woojin Jun and Daniel Wolfe (defendants) received a call concerning Fermin Valenzuela, a suspicious person at a laundromat. Wolfe confronted Valenzuela, who had a glass pipe and a screwdriver in his possession and who appeared to be in a chemically altered state. Valenzuela resisted arrest. The resulting altercation between Valenzuela, Wolfe, Jun, and supervising officer Daniel Gonzalez (defendant) ended in Valenzuela’s death by chokehold. Valenzuela’s father and children (the Valenzuela family) (plaintiffs) brought suit against the three officers and the City of Anaheim (defendant), alleging excessive force and wrongful death. The federal district court found in the Valenzuela family’s favor, awarding $13.2 million in damages. The award was based on multiple theories of liability, including loss of life, which accounted for $3.6 million. The officers and the city appealed to the United States Court of Appeals for the Ninth Circuit, citing a ban on recovery for a decedent’s loss of life in California state law, which was controlling unless it existed in conflict with federal damages law.
Rule of Law
Issue
Holding and Reasoning (Owens, J.)
Dissent (Lee, J.)
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