Judge: Gail Killefer, Case: 19STCV35345, Date: 2023-01-30 Tentative Ruling



Case Number: 19STCV35345    Hearing Date: January 30, 2023    Dept: 37

HEARING DATE:                 January 30, 2023   

CASE NUMBER:                  19STCV35345

CASE NAME:                        Eddie Rankin, III v. California Department of Corrections, et al.

MOVING PARTY:                Defendant, California Department of Corrections

OPPOSING PARTY:             Plaintiff, Eddie Rankin III

TRIAL DATE:                        March 28, 2023

PROOF OF SERVICE:          OK

                                                                                                                                                           

MOTION:                               Defendant’s Motion for Summary Judgment  

OPPOSITION:                       January 4, 2023

REPLY:                                  January 17, 2023

                                                                                                                                                           

TENTATIVE:                         CDCR’s motion is granted. CDCR is to give notice and prepare a proposed judgment.

                                                                                                                                                           

Background 

 

This action arises in connection with the incarceration of Eddie Rankin III (“Plaintiff”).  Plaintiff alleges that he was incarcerated by Defendant California Department of Corrections and Rehabilitation (“CDCR”) and under its medical care from approximately 2002 to January 2019 and that he was partially paralyzed from the waist down prior to his incarceration.  

 

According to Plaintiff’s Complaint, Plaintiff was not feeling well on or about September 29, 2018, and requested medical assistance (hereinafter the “Incident”).  CDCR’s guard, Amir Kardouni (“Kardouni”) allegedly responded to Plaintiff’s request by calling Plaintiff derogatory names and dropping Plaintiff to the ground in the direction of a wooden gurney. As a result, Plaintiff alleges that he landed on his neck and fractured his vertebra, resulting in additional paralysis, injuries and impairment. Additionally, the Complaint alleges that CDCR negligently hired, supervised, and/or retained the other defendants.  

 

On September 18, 2020, Plaintiff filed a Doe amendment to the Complaint naming Kardouni as Doe 1. 

 

On January 6, 2021, Plaintiff filed his First Amended Complaint (“FAC”). The FAC alleges five causes of action: (1) violation of the Bane Act (Civ. Code § 52.1); (2) violation of the Ralph Act (Civ. Code § 51.7); (3) battery against “Doe 1”; (4) negligent hiring and retention; and (5) negligent supervision.

 

On June 14, 2021, Plaintiff filed the Second Amended Complaint (“SAC”). The SAC alleges six causes of action: (1) violation of the Bane Act (Civ. Code § 52.1) against CDCR and Does 1-20; (2) violation of the Ralph Act (Civil Code § 51.7) against CDCR and Does 1-20; (3) battery against “Doe 1”; (4) negligent hiring against CDCR and Does 2-20; (5) negligent supervision against CDCR and Does 2-20; and (6) negligent retention against CDCR and Does 2-20. 

 

On October 4, 2021, Defendants’ demurrer to the SAC was sustained as to the first and second causes of action.  

 

On November 5, 2021, Plaintiff filed the operative Third Amended Complaint (“TAC”). The TAC alleges the same six causes of action.  On May 13, 2021, the court overruled CDCR’s demurrer to the TAC.

CDCR now move for summary adjudication as follows: 

1.      Plaintiff’s claims against CDCR must be dismissed because it is immune pursuant to Gov. Code. § 844.6, and section 845.6 is not applicable as medical care was summoned for Plaintiff.

2.      Plaintiff’s claims against CDCR must be dismissed because it is immune pursuant to Gov. Code. § 844.6, and section 845.6 is not applicable as Plaintiff did not need immediate medical care. 

3.      Plaintiff’s Fourth Cause of Action for negligent hiring fails as a matter of law because Kardouni was not unfit or incompetent to perform the work for which he was hired.

4.      Plaintiff’s Fourth Cause of Action for negligent hiring fails as a matter of law because CDCR did not know and should not have known that Kardouni was unfit or incompetent to perform the work for which he was hired.

5.      Plaintiff’s Fifth Cause of Action for negligent supervision fails as a matter of law because Officer Kardouni did not become unfit or incompetent to perform the work for which he was hired.

6.      Plaintiff’s Fifth Cause of Action for negligent supervision fails as a matter of law because CDCR did not know and should not have known that Kardouni became unfit or incompetent to perform the work for which he was hired.

7.      Plaintiff’s Sixth Cause of action for negligent retention fails a matter of law because Officer Kardouni was not unfit or incompetent to perform the job for which he was hired prior to September 29, 2018.

8.      Plaintiff’s Sixth Cause of Action for negligent retention fails as a matter of law because CDCR did not know and should not have known that Officer Kardouni became unfit or incompetent to perform the work for which he was hired.

9.      Plaintiff’s First Cause of Action for Violation of the Bane Act fails as a matter of law because Kardouni did not act violently against Plaintiff.

10.  Plaintiff’s First Cause of Action for Violation of the Bane Act fails as a matter of law because CDCR did not aid, abet, and/or conspire with Officer Kardouni.

11.  Plaintiff’s Second Cause of Action for Violation of the Ralph Act fails as a matter of law because Officer Kardouni did not act violently against Plaintiff.

12.  Plaintiff’s Second Cause of Action for Violation of the Ralph Act fails as a matter of law because CDCR did not aid, abet, and/or conspire with Officer Kardouni.

13.  Defendant CDCR is entitled to summary judgment on Plaintiff’s Bane Act and Ralph Act claims because Plaintiff suffered no harm as a result of Officer Kardouni’s alleged conduct.

CDCR’s notice of motion does not comply with CCP § 437c(f)(1), which provides: “A party may move for summary adjudication as to one or more causes of action within an action, one or more affirmative defenses, one or more claims for damages, or one or more issues of duty.” CDCR’s noticed issues either address multiple causes of action within one issue, or one cause of action is addressed across multiple issues. Thus, the court will address the motion pertaining to the causes of action as alleged by the TAC.  

Evidentiary Objections 

 

CDCR’s Objections to Declaration of Plaintiff 

Overruled: Objections 2, 4, 6.

Sustained: Objections 1, 5.

Sustained-in-part:  Objection 3: sustained-in-part as to everything after “false.” 

 

CDCR Objections to Declaration of Reginald Terry 

Overruled:  Objections 7, 8, 10.

Sustained:  Objection 9

 

Objections to Depositions Excerpts of Kardouni

                Overruled: Objection 11.  

 

Objections to Plaintiff’s Materials and Additional Disputed Material Facts

Overruled: Objections 13-19,  

Sustained: Objections 12, 20-22.

 

Discussion

I.                   Legal Authority

“The purpose of the law of summary judgment is to provide courts with a mechanism to cut through the parties' pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.”  (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.)  CCP § 437c(a) provides: 

 

A party may move for summary judgment in any action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding.  The motion may be made at any time after 60 days have elapsed since the general appearance in the action or proceeding of each party against whom the motion is directed or at any earlier time after the general appearance that the court, with or without notice and upon good cause shown, may direct….  The motion shall be heard no later than 30 days before the date of trial, unless the court for good cause orders otherwise.  The filing of the motion shall not extend the time within which a party must otherwise file a responsive pleading. 

 

A motion for summary judgment may be granted “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”  (CCP § 437c(c).)   

 

“The motion shall be supported by affidavits, declarations, admissions, answers to interrogatories, depositions, and matters of which judicial notice shall or may be taken.  The supporting papers shall include a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed.  Each of the material facts stated shall be followed by a reference to the supporting evidence.  The failure to comply with this requirement of a separate statement may in the court’s discretion constitute a sufficient ground for denial of the motion.”  (CCP § 437c(b)(1); see also Cal. Rules of Court, rule 3.1350(c)(2) & (d).)   

 

In analyzing motions for summary judgment, courts must apply a three-step analysis: “(1) identify the issues framed by the pleadings; (2) determine whether the moving party has negated the opponent's claims; and (3) determine whether the opposition has demonstrated the existence of a triable, material factual issue.”  (Hinesley v. Oakshade Town Center (2005) 135 Cal.App.4th 289, 294 (Hinesley).)  CCP § 437c(p)(2) provides:

 

A defendant or cross-defendant has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action.  Once the defendant or cross-defendant has met that burden, the burden shifts to the plaintiff or cross-complainant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.  The plaintiff or cross-complainant shall not rely upon the allegations or denials of its pleadings to show that a triable issue of material fact exists but, instead, shall set forth the specific facts showing that a triable issue of material fact exists as to the cause of action or a defense thereto. 

 

The court must “view the evidence in the light most favorable to the opposing party and accept all inferences reasonably drawn therefrom.”  (Hinesley, 135 Cal.App.4th at p. 294; Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389 [Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.”].)  A motion for summary judgment must be denied where the moving party’s evidence does not prove all material facts, even in the absence of any opposition (Leyva v. Sup. Ct. (1985) 164 Cal.App.3d 462, 475) or where the opposition is weak (Salasguevara v. Wyeth Labs., Inc. (1990) 222 Cal.App.3d 379, 384, 387).   

 

II.                Factual Summary

The majority of the circumstances surrounding this matter are not disputed by the parties.

It is undisputed that Plaintiff was a prisoner in CDCR custody on September 29, 2018, based upon a conviction of voluntary manslaughter.  During the commission of this crime, Plaintiff was also shot, which left him partially paralyzed prior to his entry into CDCR custody. (Defendant’s Separate Statement of Material Facts; Plaintiff’s Separate Statement of Material Facts & Additional Material Facts (together “MF”) ¶1.) The parties do not dispute Plaintiff made a first request for medical care on September 29, 2018 and medical care was provided to him. (MF ¶2.) After returning to his cell that day, Plaintiff made another request for medical care—the parties dispute whether the request was made “immediately” upon his return. (MF ¶3.)

Regarding his request, the parties do not dispute Plaintiff called for “man down” to indicate an emergency situation. (MF ¶4.) The parties do not dispute that Officer Legge arrived first and responded by summoning medical care and that Kardouni arrived after medical care was summoned.  The parties dispute Kardouni’s course of conduct after entering Plaintiff’s cell. (MF ¶¶ 7-8.) Plaintiff alleges that “after medical care was summoned and arrived to transport him, Officer Kardouni slammed him onto a gurney.” (MF ¶7.)

It is also undisputed Officer Kardouni has been a sworn public safety officer with CDCR since 2016; met CDCR’s age and educational requirements prior to hire; Officer Kardouni’s application process included a written test, an in-person interview, and a background investigation; Kardouni does not have a criminal history; has never been fired, including from his employment as a police officer at Patton State Hospital; Officer Kardouni was not prohibited from possessing, using, or having in his custody or control a firearm prior to his hire by CDCR; and that CDCR conducted a background check prior to hiring Officer Kardouni, which he passed. (MF ¶¶15-21.)

Plaintiff did not previously file an inmate complaint against Officer Kardouni. (MF ¶35.) Officer Kardouni has participated in training provided by CDCR during his employment, including force techniques and when a use of force may or may not be used. (MF ¶41.)

The parties also do not dispute that Plaintiff was found, on several occasions, to be guilty of rules violations for possession of controlled substances during his time in CDCR custody. (MF ¶¶51-62.)

Plaintiff informed LCSW J. Graupmann that Officer Kardouni “grab[bed] me by the shoulders and threw me on the board. . . . He does the same things to my legs.” (MF ¶71.) During Plaintiff’s interview with Sergeant Kang, he stated that upon his return to his cell, he “fell out.” Plaintiff called for man down, as did others. Plaintiff stated that Officer Legge responded and summoned medical care. After medical care arrived, Officer Kardouni picked Plaintiff up by the shoulders and slammed his shoulders into the wall and gurney, then picked up his legs and slammed them into the wall and gurney. (MF ¶73,74.)

The parties dispute Kardouni’s presence at any other point throughout that day, as well as the temporal sequence of events regarding Kardouni’s arrival before or after medical care had been summoned and arrived. (MF ¶74-83.)

On October 26, 2022, an investigation into Plaintiff’s claim was initiated and Plaintiff was interviewed by Sergeant Kang that same day. (MF ¶85.) The parties dispute the thoroughness of Sergeant Kang’s investigation. (MF ¶¶86-90.)

III.             Analysis

 

A.     First Cause of Action: Violation of Bane Act

Civil Code § 52.1 (the “Bane Act”) allows an individual to sue for damages if a person or persons “interferes by threat, intimidation, or coercion, or attempts to interfere by threat, intimidation, or coercion, with the exercise or enjoyment by any individual or individuals of rights secured by the Constitution or laws of the United States, or of the rights secured by the Constitution or laws of this state….”  (Civ. Code § 52.1(a), (b).)  “The essence of a Bane Act claim is that the defendant, by the specified improper means (i.e., ‘threat[], intimidation or coercion’), tried to or did prevent the plaintiff from doing something he or she had the right to do under the law or to force the plaintiff to do something that he or she was not required to do under the law.”  (King v. State of Cal. (2015) 242 Cal.App.4th 265, 294.)   

Under Gov. Code § 844.6, a “public entity” is not liable for “an injury to any prisoner” unless certain exceptions apply, including as provided in Gov. Code § 845.6. (Gov. Code § 844.6(a)(2).) However, “[n]othing in this section exonerates a public employee from liability for injury proximately caused by his negligent or wrongful act or omission.” (Gov. Code § 844.6(d).)

Here, CDCR first argues section 844.6 affords CDCR immunity from this action, as Plaintiff’s claims do not meet the “narrow exception” provided by section 845.6. (Motion, 15-16; citing Castaneda v. Department of Corrections & Rehabilitation (2013) 212 Cal.App.4th 1051, 1070.)

Specifically, the Castaneda court found:

“Public entities in California are not liable for tortious injury unless liability is imposed by statute. (§ 815.) ‘[S]overeign immunity is the rule in California; governmental liability is limited to exceptions specifically set forth by statute.’ (Cochran v. Herzog Engraving Co. (1984) 155 Cal.App.3d 405, 409.) Section 844.6, subdivision (a)(2) establishes the State's immunity to liability for injuries to prisoners. Section 845.6 both affirms the public entity immunity to liability for furnishing medical care, and creates a narrow exception to that immunity.

Section 845.6 states in relevant part, ‘Neither a public entity nor a public employee is liable for injury proximately caused by the failure of the employee to furnish or obtain medical care for a prisoner in his custody; but, except as otherwise provided by Sections 855.8 and 856 [concerning mental illness and addiction], a public employee, and the public entity where the employee is acting within the scope of his employment, is liable if the employee knows or has reason to know that the prisoner is in need of immediate medical care and he fails to take reasonable action to summon such medical care.’

The first clause of section 845.6 establishes the immunity generally of both the public entity and its employees from liability ‘for injury proximately caused by the failure of the employee to furnish or obtain medical care for a prisoner in his custody.’ The second phrase creates a limited public-entity liability when: (1) the public employee ‘knows or has reason to know [of the] need,’ (2) of ‘immediate medical care,’ and (3) ‘fails to take reasonable action to summon such medical care.’ [internal citations omitted]

Section 845.6 is very narrowly written to authorize a cause of action against a public entity for its employees' failure to summon immediate medical care only, not for certain employee's malpractice in providing that care. ... Thus, section 845.6 creates out of the general immunity a limited cause of action against a public entity for its employees' failure to summon immediate medical care only. The statute does not create liability of the public entity for malpractice in furnishing or obtaining that medical care. [internal citations omitted; see also Nelson v. State of California, supra, 139 Cal.App.3d at pp. 78–79, [state liable for failure to summon medical care; medical malpractice causes of action may only be brought against employee providing care].) Nor does the statute make the State “ ‘vicariously liable for the medical malpractice of its employees. Although the State is required to pay the judgment assessed against its employees for medical malpractice committed against a prisoner, the State is immune from suit directly.’’

A narrow reading of section 845.6 is also compelled as a matter of statutory interpretation. First, the duty to summon is presented as the exception to the broad, general immunity for failing to furnish or provide medical care. Second, section 845.6 imposes the duty to summon on ‘public employees’ generally, not medical care providers in particular. Many such public employees are ‘[p]rison authorities [who] do not have the medical training to know whether a prisoner's medical condition has been properly diagnosed and treated.’ The Legislature could not have contemplated imposing a duty to do more than to summon medical care as it imposed that duty on ‘public employees,’ such as prison authorities, generally.

The distinction between failure to summon medical care—for which the State can be held liable under section 845.6—on the one hand, and negligence in providing care—for which the State is immune—on the other hand, was addressed in Nelson v. State of California, (1983) 139 Cal.App.3d 72. There, the plaintiff was incarcerated when he complained of various medical problems that were symptoms of diabetes. (Id. at p. 75.) He filed a tort claim reciting the  ‘‘failure of the Department of Corrections to diagnose and treat or allow claimant to maintain his ongoing medications.’’ (Id. at p. 80.) The plaintiff's ensuing complaint was based on the failure to summon immediate, competent medical care under section 845.6. (Nelson v. State of California, supra, at p. 78.) Nelson held ‘as a matter of statutory interpretation, that the act of a doctor or other such professional who, in the course of treatment of a prisoner, fails to prescribe and/or provide the correct medication is [not] the legal equivalent to a failure to summon medical care as set forth in [§ 845.6].’ (Id. at pp. 80–81.) ‘Once a practitioner has been summoned to examine and treat a prisoner, he or she is under a duty to exercise that degree of diligence, care, and skill such as is ordinarily possessed by other members of the profession. Failure to do so is malpractice. Failure of a practitioner to prescribe or provide necessary medication or treatment to one he or she has been summoned to assist is a breach of such duty and as such is also medical malpractice and clearly, as a matter of the plain meaning of the statutory language, cannot be characterized as a failure to summon medical care.’” (Castaneda v. Department of Corrections & Rehabilitation (2013) 212 Cal.App.4th 1051, 1069–1071.)

CDCR argues Plaintiff’s claims fail here “because medical care was summoned prior to his allegations of excessive force by [Kardouni] and because Plaintiff was not in need of immediate medical care...” (Motion, 15-17.) CDCR further contends Plaintiff cannot avail himself of the section 845.6 exception as “medical care was summoned for Plaintiff prior to the alleged battery.” (Id.) CDCR here also contends Plaintiff’s actions, in laying down to specifically indicate a “man down” emergency after returning from his first medical care that day, “establish that he was not in immediate need of medical care, and instead, was manipulating prison staff into responding to his complaint, about a medical issue for which he already received medical care earlier.” (Motion, 18.)

CDCR further contends Plaintiff’s alleged inconsistent statements here show the first cause of action must fail as a matter of law since the changes are so numerous in times and ways, “such that a trier of fact would be precluded from believing his allegations.” (Motion, 22.) CDCR points to Plaintiff’s alleged inconsistent statements regarding the type of medical care he was requesting, for which ailment, number of interactions with Officer Kardouni on that day, and the alleged battery, as well as Plaintiff’s alleged history of controlled substance use and falling, to emphasize a lack of credibility here. (Motion, 22-25.)

Lastly, CDCR contends Plaintiff cannot point to any evidence of an alleged cover-up of Kardouni’s actions as Sergeant Kang’s investigation showed no other individuals supported Plaintiff’s allegations and Plaintiff has failed to show how the CDCR created an official or unofficial policy to deprive Plaintiff of medical care. (Motion, 25.) Here, CDCR concludes by arguing there is no evidence of a neck fracture or injury to the spine caused by an alleged assault on September 29, 2018, and the medical record shows Plaintiff was treated for an infection in his neck. (Motion, 26-27.)

In opposition, Plaintiff points to new amendment to section 844.6, Senate Bill 2, and its legislative history to show the legislature’s desire to limit the immunity scope of the section more strictly. (Opposition, 7-9.) Plaintiff contends public entity liability under section 845.6 is alleged as the basis for Plaintiff’s claims in the TAC, which pass the summary judgment standard. (Opp., 10.) Plaintiff argues “CDCR’s arguments are not legal but factual, relying heavily on inferences and credibility evaluations. Reliance on inferences is only proper where it is the only plausible inference, drawn from undisputed facts.” (Id.; citing Anderson v. Metalclad Insulation Corp., (1999) 72 Cal. App. 4th 284, 297.) Here, Plaintiff argues “CDCR’s actual or constructive knowledge of Plaintiff’s need for medical care, and whether reasonable action was taken” are all questions of fact which should be determined at the trial stage. (Id.) Plaintiff also points to specific uniforms worn by disabled prisoners, and testimony by the responding officers regarding Plaintiff’s statements on the day to show “[w]hether or not Rankin’s need for medical care was ‘immediate’ enough to fall under Government Code 845.6 is a question of fact for the jury.” (Opp., 11.) Here, Plaintiff clarifies his claims are based on “whether Officer Khardouni acted reasonably once he became aware that Plaintiff was in need of medical care.” (Opp., 12-3.)

In reply, CDCR argues Plaintiff fails to support his contention that any recent amendment section should apply retroactively to Plaintiff’s claims here. (Reply, 6-7.) CDCR further argues section 845.6 remains inapplicable here as a matter of law since Plaintiff’s testimony allegedly contradicts the TAC’s allegations. (Id.) Namely, CDCR argues “Plaintiff was exaggerating his medical need – consistent with the drug-seeking behaviors observed soon after he began the weaning process for his morphine prescription. Therefore, there was no immediate need for medical care required to permit liability here.” (Reply, 7.) However, CDCR fails to provide sufficient authority to support this contention.

CDCR argues Plaintiff’s testimony shows medical care was summoned prior to Kardouni’s arrival. (Reply, 7-8.) Here, the CDCR points to Plaintiff’s deposition testimony, where he stated Officer Kardouni was the first to arrive after the medical alarm, but “Officer Legget [sic] was the one who initiated the medical alarm... he checked on my status first and then proceeded with... the alarm.” (Chen Decl., Exh. D, 28:2-16.) As a result, CDCR argues the circumstances of Castaneda are similar to our circumstances here, and section 845.6 does not apply as the alleged battery “occurred after medical care was summoned...” (Reply, 7-8.) The court agrees.

Viewing the evidence submitted in the light most favorable to Plaintiff, the court finds no triable issues exist with regard to the first cause of action. Specifically, the court finds no triable issues exist with regard to whether section 845.6 applies, and more specifically, as to whether the alleged battery which would impose liability upon the public entity occurred after medical care was summoned. Although Plaintiff correctly contends that any evaluation of the reasonableness of summoning medical care or the access to medical care in these circumstances are questions of act for determination at the trial stage, Plaintiff’s own testimony establishes the medical alarm was rung – and medical care was summoned -- before Kardouni arrived. Whether Plaintiff actually needed immediate care, whether Plaintiff sustained actual injuries, and whether Kardouni acted reasonably are therefore no longer relevant questions for this court at the summary judgment stage, as CDCR has made clear section 844.6 applies immunity to the CDCR in this action.

For these reasons, CDCR’s motion is granted as to this issue. 

B.     Second Cause of Action: Violation of Ralph Act

Civil Code § 51.7 (the “Ralph Act”) provides that all persons have the right to be free of “violence, or intimidation by threat of violence, committed against their persons,” committed because of their political affiliation or any characteristic defined in Civil Code section 51. A person aggrieved under the Ralph Act may bring a civil action to recover damages, “a civil penalty of $25,000, exemplary damages, and an award of attorney fees.” (D.C. v. Harvard-Westlake School (2009) 176 Cal.App.4th 836, 856; Civil Code §§ 52(b), (c).)

CDCR contends that Plaintiff’s second cause of action also fails as section 844.6’s liability extends to Plaintiff’s second cause of action as it is “premised on alleged violence by Officer Kardouni and not the failure to summon immediate medical care.” (Motion, 17.) CDCR, in reply, reiterates their contentions that sections 845.6 and 815.6 afford Plaintiff no relief here as the shielding language of section 844.6 remain very clear. (Reply, 7-8.)

Having granted CDCR’s motion as to the first cause of action on a finding of immunity for CDCR pursuant to section 844.6, the court now again finds there are no triable issues of material fact as to Plaintiff’s second cause of action as well for identical reasons.

For these reasons, CDCR’s motion is also granted as to this issue.  

C.     Fourth, Fifth, Sixth Causes of Action: Negligent Hiring and Retention, Negligent Supervision

“An employer may be liable to a third person for the employer's negligence in hiring or retaining an employee who is incompetent or unfit. [Citation.]” (Roman Catholic Bishop v. Superior Court (1996) 42 Cal.App.4th 1556, 1564–1565.) Negligence liability will be imposed upon the employer if it “knew or should have known that hiring the employee created a particular risk or hazard and that particular harm materializes.” (Doe v. Capital Cities (1996) 50 Cal.App.4th 1038, 1054.) As such, “California follows the rule set forth in the Restatement Second of Agency section 213, which provides in pertinent part: ‘A person conducting an activity through servants or other agents is subject to liability for harm resulting from his conduct if he is negligent or reckless: ... [¶] (b) in the employment of improper persons or instrumentalities in work involving risk of harm to others[.]’ (Ibid.)” (Evan F. v. Hughson United Methodist Church (1992) 8 Cal.App.4th 828, 836.)  Liability for negligent supervision and/or retention of an employee is one of direct liability for negligence, not vicarious liability.  (Delfino v. Agilent Technologies, Inc. (2006) 145 Cal.App.4th 790, 815.) 

 

CDCR contends that Plaintiff’s fourth, fifth, and sixth causes of action are similarly shielded by section 844.6’s immunity provision “because those claims are premised on the theory that Officer Kardouni had a tendency for violence and should have been supervised more closely to ensure that Plaintiff was not subject to excessive force, battery, and/or civil rights violations. These claims make no allegations as to a history or knowledge by CDCR that Officer Kardouni had a history of failure to summon medical care. These claims should also be dismissed.” (Motion, 17-18.)

 

In opposition, Plaintiff fails to show, or provide authority to guide this court, that the fourth, fifth, and sixth causes of action do not fall under the immunity language of section 844.6. (Opp., 17-18.)   

 

The court finds Plaintiff’s fourth, fifth, and sixth causes of action also fail as a matter of law based on Gov. Code section 844.6’s immunity provision denying any imposition of liability upon CDCR here. (See generally Castaneda v. Department of Corrections & Rehabilitation, supra, 212 Cal.App.4th at 1069–1072.) Plaintiff fails to show how the immunity does not extend to CDCR in these circumstances, and thus the court finds there are no triable issues of material fact as to these claims against CDCR, a public entity.

 

For these reasons, CDCR’s motion is also granted as to these issues.  

 

Conclusion

 

CDCR’s motion is granted. CDCR is to give notice.