Filed Date: Oct. 30, 2008
Closed Date: Jan. 11, 2019
Clearinghouse coding complete
On October 30, 2008, a pre-trial detainee of the Los Angeles City Central Jail filed a pro se complaint in the U.S. District Court for the Central District of California against Los Angeles County officials, the Los Angeles County Sheriff, and a medical doctor that served the jail. The plaintiff alleged that the conditions of confinement, specifically lack of a bed and infestation, violated his constitutional rights. Additionally, the plaintiff alleged he was denied prompt medical care when the defendant doctor failed to supply prescribed medication for 43 days. The plaintiff sued under 42 U.S.C. § 1983 and Ex parte Young, seeking compensatory damages in the amount of $33,000 and punitive damages in the amount of $333,000.
The plaintiff had entered jail custody in July 2006, and as he was being processed, there was a string of racially charged violent disturbances at several jail facilities. Officials locked down multiple facilities, which delayed in-processing. As a result, the plaintiff was held at a facility without sufficient bench space for sleeping, and no beds or mattresses. He slept on the floor.
On November 9, 2009, the defendants filed a motion to dismiss on the grounds that the plaintiff failed to exhaust his administrative remedies, which the Magistrate Judge Alicia G. Rosenberg recommended be granted in part and denied in part. On July 6, 2010, the District Court (Judge John F. Walter) adopted the Magistrate Judge's report and dismissed all claims except the claim against the Sheriff in his individual and official capacities for failure to provide adequate sleeping accommodations.
Later that year, on September 14, the plaintiff filed a second amended complaint against the Los Angeles County Sheriff in his official and individual capacities, alleging substantively the same claims for conditions of confinement. On August 21, 2011, in response to the defendants' motion to dismiss the second amended complaint and after Magistrate Judge Rosenberg's Report and Recommendation (2011 WL 3607461), the District Court dismissed all claims except the claim against the Sheriff in his individual capacity for failure to provide adequate sleeping conditions. 2011 WL 3607212.
On April 30, 2013, the defendant filed a motion for summary judgment on the remaining claim. A magistrate judge found that the newly supplemented record demonstrated that the Los Angeles County jail had faced difficult exigent circumstances in the aftermath of the disturbances and lockdown, and that this meant there had been no constitutional violation. The District Court agreed, dismissing the case on July 18, 2013. 2013 WL 3791419.
A few months later, on July 30, the plaintiff appealed to the U.S. Court of Appeals for the Ninth Circuit. After appointing counsel to represent the plaintiff pro bono, on January 11, 2019, the Ninth Circuit affirmed in an opinion by Judge Consuelo Callahan. 913 F.3d 852. In light of the exigent circumstances, the opinion explained, there was no constitutional violation, and the sheriff was entitled to qualified immunity.
The case is now closed.
Summary Authors
Anjali Biala (11/7/2013)
Will McCartney (11/4/2019)
Venesa Haska (12/24/2023)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5745665/parties/maurice-p-olivier-v-gloria-molina/
Rosenberg, Alicia G. (California)
Walter, John F. (California)
Olivier, Maurice Pierre (California)
Beach, Paul B (California)
Lee, Daniel (California)
See docket on RECAP: https://www.courtlistener.com/docket/5745665/maurice-p-olivier-v-gloria-molina/
Last updated March 20, 2025, 10:49 a.m.
State / Territory: California
Case Type(s):
Special Collection(s):
Key Dates
Filing Date: Oct. 30, 2008
Closing Date: Jan. 11, 2019
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A person detained pre-trial at the Los Angeles City Central Jail.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: Yes
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Los Angeles County Jail (Los Angeles), County
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
General/Misc.:
Sanitation / living conditions
Medical/Mental Health Care: