$1.2 Million in Settlements Reached in Suit Over Sacramento Jail Murder
by Douglas Ankney
On February 7, 2025, California’s Sacramento County made a $600,000 offer of judgment that was accepted by the Plaintiffs in a suit filed over a detainee’s murder at the County lockup in 2019. The Estate of Bryan Debbs had earlier accepted another $600,000 settlement offer from the University of California—Davis (UCD), which was contracted to provide medical care to the mentally ill detainee and others held in custody by the County Sheriff’s Office (SCSO).
Debbs was taken into custody at the Jail on May 24, 2019, and assigned to the outpatient psychiatric unit (OPP) by Jail Psychiatric Services (JPS) staffers contracted from UCD. They put him in a cell with fellow OPP detainee Christian Ento. The two were transferred to the inpatient psychiatric unit (2P) on July 7, 2019, on the order of psychiatrist Dr. Jason Roof, who diagnosed both men as “gravely disabled.”
Debbs and Ento were housed in Cell P1, the only double-bunked cell in the 2P Unit, where security measures required JPS staff to visually observe the detainees in their cells every 15 or 30 minutes, as determined by the psychiatrist—though visual observations could be supplemented with closed-circuit TV monitoring.
On July 8, 2019, JPS nurses Sandra A. Venus and Esther W. Muiruri were on duty in the 2P Unit when a 3:30 a.m. check found Ento on top of Debbs, assaulting him. SCSO deputies responded to Venus’ call for assistance. Jail surveillance video later revealed that Ento assaulted Debbs for 20 minutes, strangling him and stabbing his eyes with a pencil at least 40 times. Debbs died from his injuries on August 3, 2019.
His mother, Shelley Debbs, and fellow Plaintiff Rigoberto Arriaga filed suit in federal court for the Eastern District of California in November 2020, accusing the SCSO and Sheriff Scott R. Jones, as well as Venus and Muiruri, of failing to protect Debbs and failing to summon medical care for him, in violation of his rights under the Eighth Amendment and California Government Code (CGC) § 845.6, respectively. Faulting a governmental policy or custom, they sought to extend liability to the County for the civil rights violation under Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658 (1978). The complaint also lodged claims for negligence and wrongful death against Jones, Venus, and Muiruri.
The Defendants moved for summary judgment, arguing that (1) the SCSO was not a person who could be sued; (2) Plaintiffs’ Monell claim failed because there was no allegation that any Defendant employee committed an Eighth Amendment violation or that a custom or policy was the “moving force behind a constitutional violation;” (3) there was no evidence that a County employee was aware of a serious medical need and failed to summon care; and (4) the negligence claim against Jones was barred by CGC §§ 820.2 and 820.8.
The Court declined to dismiss the SCSO from the case, agreeing with Plaintiffs that the Ninth Circuit recognized “both California municipalities and police departments are ‘persons’ amenable to suit.” The Monell claim was also sustained, since the Ninth Circuit had held municipalities liable for damages in which no individual was held liable, too.
As to the Defendants’ argument that there was no evidence an employee failed to summon medical care, the Court explained that the cell-check and TV monitoring policies, coupled with the knowledge that the two men locked in a cell together were “gravely disabled,” presented “triable issues as to whether the County had reason to know sooner that Debbs needed immediate medical care.”
Finally, the Defendants argued that the negligence claim against Jones was barred by the discretionary function exception under CGC § 820.2. But the Court said that the exception wasn’t available, since no required showing was made that Jones “consciously balanc[ed] the risks and advantages” of an “actual policy decision.” To the contrary, Plaintiffs pointed to case law holding that “classification and placement” in a prison or jail is “not subject to section 820.2 immunity.” Accordingly, the Court denied Defendants’ motion for summary judgment on June 20, 2023. See: Est. of Debbs v. Cty. of Sacramento, 2023 U.S. Dist. LEXIS 107230 (E.D. Cal.).
Plaintiffs then proceeded to reach settlement agreements with Defendants, starting with UCD, which reportedly agreed in July 2024 to pay $600,000 to settle claims that it “fail[ed] to provide inmates with mental health and medical care, fail[ed] to appropriately assign inmates to cells who are suffering from mental illnesses, and fail[ed] to promptly transfer inmates to psychiatric hospitals when they are at risk of serious harm.”
The subsequent payment by the County brings the total paid for Debbs’ murder to $1.2 million, which includes costs and fees for the Estate’s attorneys, Mark E. Merin and co-counsel from his eponymous Sacramento firm, Paul H. Masuhara III. See: Est. of Debbs v. Cty. of Sacramento, USDC (E.D. Calif.), Case No. 2:20-cv-01153.
Additional source: Sacramento Bee
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