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California: Denial of Bed During Jail Disturbances Not a Constitutional Violation

by David M. Reutter

On January 11, 2019, the Ninth Circuit Court of Appeals affirmed a grant of summary judgment to the defendants in a civil rights action alleging a pretrial detainee was denied a bed during his three-and-a-half-day stay at the Los Angeles County Inmate Reception Center (IRC).

Maurice Olivier was rearrested on July 12, 2006 after being erroneously released five days earlier. Upon his arrival at IRC, it was determined that his medical needs required him to be housed at the Men’s Central Jail (MCJ). While Olivier was being processed at IRC, prisoners in Los Angeles County’s jail system “repeatedly divided themselves along racial lines and fought.” The violence persisted for about three days and caused lockdowns at MCJ and other facilities, delaying intake processing.

Olivier testified that he was placed in a cell with benches that provided “inadequate space to accommodate the number of detainees at IRC.” He was forced to sleep on the floor and was not provided (nor did he request) any type of mattress or bedding over his three-and-a-half days at the jail. After the lockdowns began on July 13, 2006, the first transfers to other jails started around 2:00 a.m. on July 16. Olivier was transferred to MCJ on the afternoon of July 16.

In his civil rights complaint, Olivier alleged claims related to his extended stay at IRC and events following his transfer to MCJ. By the summary judgment stage, only his claim related to being forced to sleep on the floor in the medical intake area at IRC remained.

The district court held the “record conclusively demonstrated that the Los Angeles County jail system experienced exigent circumstances due to the disturbances and lockdowns.” It therefore granted the defendants’ motion for summary judgment.

On appeal, the Ninth Circuit affirmed in a lengthy and detailed decision. 

The appellate court noted that in the “context of disturbances by inmates and lockdowns, we have held that such issues can delay detention facility procedures and temporarily restrict certain rights without violating the Eighth Amendment.” The Court of Appeals found jail officials were within their authority to maintain security when they imposed the lockdowns that delayed Olivier’s transfer to MCJ and left him without a bed. The Court wrote that Olivier was “promptly transferred to permanent housing after the disturbances had been controlled,” when normal jail operations resumed.

The Ninth Circuit also found Olivier had failed to demonstrate “that the law regarding floor sleeping, in the context of exigent circumstances, was or is clearly established.” Therefore, he had not shown “that a genuine issue of material fact exists as to whether [then-Sheriff Lee] Baca was entitled to qualified immunity.” The district court’s order was affirmed. See: Olivier v. Baca, 913 F.3d 852 (9th Cir. 2019). 

Related legal case

Olivier v. Baca