Ninth Circuit Holds Jail Design Constitutional Monell Policy

Apr 15, 2016 - Significant Cases by

In Castro v. County of Los Angeles, 785 F.3d 336 (9th Cir. 2015), the Ninth Circuit held that the design of a jail cell constitutes a formal policy for purposes of Monell liability. But because the Eighth Amendment’s deliberate-indifference element is a subjective standard, there must be proof that a policymaker with authority over the jail was actually aware that the design posed a substantial risk of serious harm. The court also held that the deliberate-indifference standard for constitutional violations and the reckless-indifference standard for punitive damages in § 1983 cases are synonymous. Thus, juries “have the discretion to impose punitive damages if they believe further punishment above and beyond compensatory damages is appropriate, without having to make any additional factual findings.”

Tags: Case Update, Prison Litigation