by Sam Rutherford

On December 2, 2025, the U.S. Court of Appeals for the Ninth Circuit affirmed a $3,840,000 jury verdict for the Estate of a San Bernardino County jail detainee who died from untreated symptoms from acute alcohol withdrawal.

William Enyart’s family members called 911 on July 27, 2022, when an argument erupted at the family home in Apple Valley, California. The argument started when they confronted William about his excessive alcohol use. San Bernardino County Sheriff’s Department (SBSD) Dep. Ronald Conley was the first to arrive, and a scuffle ensued when he approached William. Conley smelled alcohol on William’s breath and believed he was intoxicated. Conley called for back-up.

Fellow Deputy Cara Umphlett responded to the call. William had calmed down by that time, so she did not interact with him directly. Instead, she spoke with his parents. Mrs. Enyart told Umphlett that William was at risk of fatal alcohol withdrawal symptoms, like cardiac arrest or seizure, and that he should be hospitalized rather than jailed. It is unclear whether Umphlett communicated this information to Conley.

Paramedics were also summoned, and when they questioned William about his alcohol use, he refused to answer. The paramedics then cleared William for arrest, and Conley transported him to the County’s High Desert Detention Center (HDDC). Conley did not inform medical staff conducting the booking intake about William’s alcohol use, and she even answered “no” on a questionnaire asking if the arrestee was under the influence. William also denied using drugs or alcohol during this screening.

His parents called Conley several times after William’s arrest to express their concern that he could suffer symptoms from alcohol withdrawal. Conley did not document or communicate this concern to anyone. The Enyarts also called HDDC numerous times, expressing their concerns to Deputy Troy Skaggs and Custody Specialist April Snow. But they made no effort to investigate these concerns or communicate them to the jail’s medical staff. They also failed to inform the Enyarts how to go about contacting medical staff directly.

As William’s condition deteriorated, he was transferred from HDDC to the West Valley Detention Center (WVDC), a facility with more robust medical and mental healthcare services. He continued to deny any alcohol or drug abuse. But his condition continued to decline over the next several days. He died in a cell at WVDC on August 1, 2022.

Suit Filed,
Motion to Dismiss Denied

His parents, Frances and Gregory Enyart, and his sister Amanda, acting as guardian ad litem to William’s minor daughter, then filed suit in the U.S. District Court for the Central District of California. Proceeding under 42 U.S.C. § 1983, they accused the County and several of its jail employees of deliberate indifference to Enyart’s serious medical condition, in violation of his Fourteenth Amendment rights. They also sought to extend liability to the County under Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978), for failing to implement policies that might have prevented the death.

Importantly, the district court noted that a government employee acts with deliberate indifference toward a jail detainee by: (1) making an intentional decision with respect to the conditions of confinement which (2) put the detainee at substantial risk of serious harm and to which (3) the employee showed reckless disregard, per Russell v. Lumitap, 31 F.4th 729 (9th Cir. 2022), thereby (4) causing the detainee’s injuries.

Plaintiffs argued that Defendants fell under this standard by failing to respond to the concerns that they voiced. Defendant jailers insisted that they were at worst negligent for failing to relay the information to jail medical staff, therefore lacking the requisite mental state of recklessness. The district court concluded that this dispute created “a triable issue of fact” that also deprived the Defendants of qualified immunity, since Ninth Circuit precedent at the time of William’s death clearly established that a government employee “who is aware that an inmate is suffering from a serious acute medical condition violates the Constitution when he stands idly by rather than responding with reasonable diligence to treat the condition,” as held in Sandoval v. Cty. of San Diego, 985 F.3d 657 (9th Cir. 2021).

In its ruling denying the Defendant jailers’ motion for summary judgment, on April 22, 2024, the district court also denied the County’s motion for summary judgment on the Monell claim, finding insufficient evidence of any policy warning that failure to relay third party medical information amounts to deliberate indifference—especially in light of other detainee deaths that Plaintiffs cited. See: Enyart v. Cty. of San Bernardino, 2024 U.S. Dist. LEXIS 74108 (C.D. Cal. 2024).

Trial and Subsequent
Proceedings

The case proceeded to trial in May 2024. Although the jury determined that none of the individual defendants were liable for violating William’s constitutional rights, it found that the County was responsible for his death, at least in part. On May 24, 2024, the jury returned a verdict awarding $400,000 for William’s pre-death pain and suffering and $6,000,000 for his loss of life; jurors also held him 40% responsible, however, resulting in a $3,840,000 award.

Post-Verdict Proceedings

The County moved for judgment as a matter of law (JNOV) or a new trial, arguing that the jury’s liability finding was irreconcilable with its refusal to find that any of the individual defendants committed a constitutional violation. But on June 11, 2024, the district court denied the motion and upheld the verdict, ruling that jurors properly blamed the County’s lack of a policy for Enyart’s death. See: Enyart v. Cty. of San Bernardino, 2024 U.S. Dist. LEXIS 183256 (C.D. Cal.).

Defendants turned to the Ninth Circuit, where it took over a year to docket the case for oral argument. That finally occurred in December 2025, and the appellate Court’s decision followed shortly thereafter. In its ruling, the Court began by noting that JNOV may be granted when “a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue,” as laid out in Fed. R. Civ. Proc. 50(a)(1).

In reviewing the verdict, the Court said that it must draw all reasonable inferences in favor of the Estate, as the non-moving party, under Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000). It must then find no “substantial evidence” to support the verdict, as held in Pavao v. Pagay, 307 F.3d 915 (9th Cir. 2002), quoting Three Boys Music Corp. v. Bolton, 212 F.3d 477 (9th Cir. 2000), to define the term as “such relevant evidence as reasonable minds might accept as adequate to support a conclusion.”

The County’s argument about the verdict’s irreconcilability was batted aside, with the Court noting that liability may “result [from] the collective inaction of the [municipality],” as held in Fairley v. Luman, 281 F.3d 913 (9th Cir. 2002). Also dismissed was a second County contention that jurors never heard the arguments filed in opposition to its motion by Plaintiffs; the Court said that Plaintiffs’ experts testified to the requirements of the California Code of Regulations, which jurors “could have reasonably concluded” had “provided the County with sufficient notice.” Accordingly, the verdict was affirmed. The Estate was represented by San Diego attorneys Grace Jun, Danielle R. Pena and Joseph M. McMullin. See: Enyart v. Cty. of San Bernardino, 2025 U.S. App. LEXIS 33560 (9th Cir.).  

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