San Diego County Files Unusual Suit Against NaphCare Over Jail Detainee’s Murder
On September 18, 2025, less than a month after losing a bid to dismiss a wrongful death suit filed by the survivors of a detainee murdered in the county lockup, San Diego County filed a crossclaim against its jail medical contractor, NaphCare, along with the firm’s subcontracted mental health care provider, Liberty Healthcare. The unusual move by the county against its jail medical contractors was the latest twist in the suit by the survivors of the dead man, Brandon Yates.
Yates, 24, was arrested in January 2024 on suspicion of burglary, after he was found sleeping in a stranger’s backyard shed. Though he was struggling with mental health and addiction issues, he was booked into the County’s Men’s Central Jail in downtown San Diego. Less than a day later, he was found naked and dead on his cell floor, his hands and feet “bound behind his back,” as the complaint later filed on his behalf recalled. His cellmate, Alvin Ruis, had tortured and sexually assaulted him, the complaint continued, before he “choked and smothered Brandon to death.”
Ruis, 36, was a “bypass inmate” supposedly not allowed contact with staff or other detainees because of multiple threats he had made since his arrest for assaulting his wife and kids. But despite a known history of worsening psychosis, violence and self-harm, Ruiz was not left alone in his cell, at least for a while. Just 60 minutes after being placed in the cell with him, Yates began ringing his cell alarm and screaming for help. But guards allegedly ignored his cries as he was “tortured, stripped naked, bound, sexually assaulted, and murdered,” the complaint said.
With the aid of attorneys Eugene G. Iredale and Julia Yoo of Iredale & Yoo, APC in San Diego, Dan and Andrea Yates filed suit on behalf of their son’s Estate in the U.S. District Court for the Southern District of California. Proceeding under 42 U.S.C. § 1983, they accused the County, along with Sheriff Kelly Martinez and other jail officials of deliberate indifference by failing to protect him from the cell mix-up, which also reflected a violation of policy and lack of training and supervision. The suit made several state-law claims, as well.
Defendant County officials moved to dismiss the complaint, arguing that its pleadings were insufficiently specific, and even if they were, jailers were entitled to qualified immunity (QI). But in its ruling on August 21, 2025, the district court rejected both arguments. As pleaded by the Plaintiffs, the facts “plausibly state a claim that Defendants were aware Mr. Yates was in danger when they placed him in the same cell as Mr. Ruis,” the district court said.
Defendants also cited an earlier ruling granting jailers QI in Estate of Ford v. Ramirez-Palmer, 301 F.3d 1043 (9th Cir. 2002), but the district court said that none of the factors in that case was present when County jailers put Yates in a cell with Ruiz; therefore, Yates’ right to protection under the circumstances was clearly established, the district court concluded, refusing to grant QI to Defendants. See: Est. of Yates v. Cty. of San Diego, 2025 U.S. Dist. LEXIS 166613 (S.D. Cal.).
Yates’ death was just the latest in a string of fatalities at the jail that have resulted in lawsuits, dating back at least to the 2019 fatal overdose of 24-year-old Elisa Serna. Her survivors sued and reached a massive $15 million settlement with the County in August 2024, as PLN reported. [See: PLN, Aug. 2025, p.21.] After that, County supervisors voted to give authority to its Citizens’ Law Enforcement Review Board (CLERB) to investigate medical and mental health providers in jail deaths—the first jail in the country where a citizen advisory board has been granted such access.
Sheriff Martinez vigorously opposed expanding CLERB’s oversight, warning that NaphCare and Liberty Healthcare might cancel their jail contracts as a result. But supervisors approved the measure anyway in September 2025. Which makes it all the more ironic that, the same month, the County then took the unusual step of suing its contractors for their roles in Yate’s death. The case remains pending, and PLN will update further developments as they unfold. See: Est. of Yates v. Cty. of San Diego, USDC (S.D. Cal.), Case No. 3:24-cv-00410.
Additional source: San Diego Union-Tribune
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Related legal cases
Est. of Yates v. Cty. of San Diego
| Cite | USDC (S.D. Cal.), Case No. 3:24-cv-00410 |
|---|---|
| Level | District Court |
Est. of Yates v. Cty. of San Diego
| Year | 2025 |
|---|---|
| Cite | 2025 U.S. Dist. LEXIS 166613 (S.D. Cal.) |
| Level | District Court |