Maddox v. City of Los Angeles
792 F.2d 1408, 21 Fed. R. Serv. 20 (1986)
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Rule of Law:
A police officer's use of force or failure to provide medical care does not violate a pretrial detainee's Fourteenth Amendment due process rights unless the conduct rises above mere negligence. The due process duty to provide medical care requires officers to take reasonable steps to secure professional medical attention, but does not impose an affirmative obligation on officers to personally administer medical procedures like CPR.
Facts:
- Police officers Lewis and Nathan encountered Donald Wilson standing naked in a busy street, believing he was under the influence of PCP.
- When they attempted to take Wilson into custody, an altercation ensued, requiring two other officers, Arzuman and Harris, to assist.
- While Officers Arzuman and Harris were transporting the handcuffed Wilson to a hospital, he became belligerent in the police car.
- The officers stopped the car on a freeway, at which point Wilson forced Officer Harris against a guardrail overlooking a steep embankment.
- Fearing he might be pushed over the guardrail, Officer Harris applied a choke hold to Wilson for twenty to thirty seconds, subduing him.
- Wilson was still for the remainder of the drive to the hospital; Officer Harris detected a pulse en route.
- Upon arrival at the hospital, Officer Harris had difficulty finding Wilson's pulse, and the officers, though trained, did not administer CPR.
- Wilson was taken to the hospital's jail ward, where medical staff commenced CPR, but he was ultimately pronounced dead.
Procedural Posture:
- Freddie Maddox, on behalf of the estate of Donald Roy Wilson, sued the City of Los Angeles and several police officers in federal district court.
- The complaint alleged a civil rights violation under 42 U.S.C. § 1983 for deprivation of life without due process, along with state claims for wrongful death and assault.
- After a nine-day trial, the jury returned a verdict in favor of all defendants.
- Maddox filed a motion for a new trial, which the district court denied.
- Maddox, as the appellant, appealed the final judgment to the United States Court of Appeals for the Ninth Circuit, with the City and officers as appellees.
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Issue:
Does a police officer violate a pretrial detainee's Fourteenth Amendment due process rights by applying a choke hold during a violent altercation and subsequently failing to personally administer CPR while transporting the detainee to a hospital?
Opinions:
Majority - Skopil, Circuit Judge
No, a police officer does not violate a pretrial detainee's Fourteenth Amendment due process rights under these circumstances. To state a claim under § 1983 for a due process violation, the official's conduct must be more than merely negligent. The court's reasoning has two main parts. First, regarding the use of force, the court, citing the Supreme Court's decisions in Daniels v. Williams and Davidson v. Cannon, held that an officer's state of mind is a relevant factor in determining if the force used was unconstitutional. Factors such as the need for force, the relationship between the need and the amount of force used, and whether the officer's motive was punitive are all part of the inquiry. Second, concerning medical care, the court held that the Due Process Clause requires officers to take reasonable steps to secure medical care for detainees, which was satisfied here by promptly taking Wilson to a hospital. Citing Revere v. Massachusetts General Hospital, the court found no authority establishing an affirmative constitutional duty for police officers to personally administer CPR, as their obligation is to secure professional medical attention, not to provide it themselves.
Analysis:
This case solidifies the principle that mere negligence is insufficient to establish a § 1983 claim for a due process violation in the context of police conduct. It clarifies that the standard is higher, requiring a more culpable state of mind like recklessness or deliberate indifference. The decision also provides a crucial distinction for law enforcement's duty to provide medical care, defining it as a duty to 'secure' care (e.g., transport to a hospital) rather than a duty to personally 'administer' it. This precedent gives officers a clearer standard in emergency situations, protecting them from constitutional liability for failing to perform medical procedures like CPR when they are actively seeking professional help for a detainee.
