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Banks v. City of Emeryville

United States District Court, N.D. California
No reporter information provided (1985)
ELI5:

Rule of Law:

Under Federal Rule of Civil Procedure 14(a), a defendant in a 42 U.S.C. § 1983 action may implead a third party for contribution or indemnity based on state law claims, even if the third party is not liable under § 1983 and there is no independent basis for federal jurisdiction.


Facts:

  • On October 31, 1982, Mercedes Banks was arrested for public drunkenness by the Emeryville City Police and placed in a temporary detention cell.
  • The cell was furnished with a mattress manufactured, distributed, or sold by various companies, including Pacific Hospital Equipment and Supply Company.
  • During Banks's detention, a fire broke out in her cell.
  • The mattress, allegedly containing highly dangerous polyurethane filling, disintegrated into burnt shreds during the fire.
  • After the fire was extinguished, Banks was found dead, charred nearly beyond recognition.
  • The City of Emeryville alleged that the fire spread too quickly to allow for a rescue due to the dangerous and defective nature of the mattress.

Procedural Posture:

  • In August 1983, plaintiffs, representing the estate of Mercedes Banks, sued the City of Emeryville and its Police Chief, John B. LaCoste, in the U.S. District Court for the Northern District of California under 42 U.S.C. § 1983.
  • The defendants filed their answer to the complaint on September 16, 1983.
  • Defendants sought and received leave from the court to file a late third-party complaint.
  • On March 8, 1985, defendants filed a third-party complaint against several companies and individuals involved in the manufacture and sale of the jail cell mattress, seeking indemnification and contribution.
  • The third-party defendants filed a motion for judgment on the pleadings to dismiss the third-party complaint.

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Issue:

Does Federal Rule of Civil Procedure 14(a) permit a defendant in a § 1983 civil rights action to implead a third party for contribution or indemnification based on state law claims, even when the third party is not liable under § 1983?


Opinions:

Majority - Spencer Williams

Yes. Federal Rule of Civil Procedure 14(a) permits a defendant in a § 1983 action to implead a third party based on state law theories of liability like contribution or indemnification. The court reasoned that Rule 14(a) allows a defendant to bring in any party 'who is or may be liable to him for all or part of the plaintiff's claim against him.' While the mattress companies (third-party defendants) could not be held liable under § 1983 because they did not act 'under color of state law,' and § 1983 itself does not create a right to indemnity, they could still be liable to the City of Emeryville under state law. The court held that the third-party claim does not need to be based on the same legal theory as the original claim; a federal civil rights claim can support a third-party claim based on state tort law. Since California law permits contribution and indemnity based on comparative fault, and a jury could find the mattress companies' actions were partially responsible for Banks's death, impleader was appropriate for the state law claims. The court exercised ancillary jurisdiction over these state law claims as they arose from the same set of operative facts as the original federal complaint.



Analysis:

This decision clarifies the scope of impleader under Rule 14(a) in the context of federal civil rights litigation. It affirms that while defendants cannot seek contribution or indemnity directly under § 1983, they can use state law as a vehicle to shift liability to third-party tortfeasors. This allows government defendants in civil rights cases to bring private actors, such as product manufacturers, into the litigation, ensuring that all potentially responsible parties are part of a single action. The ruling reinforces the broad scope of ancillary jurisdiction for defensive impleader, promoting judicial efficiency by resolving all related claims in one federal forum.

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