{"id":493,"date":"2026-01-20T12:00:00","date_gmt":"2026-01-20T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=493"},"modified":"2026-01-20T12:00:00","modified_gmt":"2026-01-20T12:00:00","slug":"hl-county-los-angeles-cd-cal-jail-overdose-death-1983-monell-deliberate-indifference","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=493","title":{"rendered":"H.L. v. County of Los Angeles \u2014 C.D. Cal. Allows Jail Drug-Death Class Claims to Proceed Against Sheriff\u2019s Deputies but Trims Medical-Care Claims"},"content":{"rendered":"
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Case<\/dt>\n
H.L. v. County of Los Angeles<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Central District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-20<\/dd>\n
Docket No.<\/dt>\n
2:25-cv-05642-ODW<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Section 1983, Monell, deliberate indifference, dangerous conditions, jail drug overdose, Bane Act, failure to summon medical care, interference with familial relations<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Daejon Morgan died on October 30, 2024, while in custody at the Los Angeles County Twin Towers Correctional Facility. Sixteen days earlier, on October 14, he had survived an opioid overdose after ingesting a pill obtained from another inmate; deputies administered Narcan and sent him to the hospital. He was returned to jail the same day and seen by jail medical staff over the following days. He died after a second suspected overdose during a phone call with his mother.<\/p>\n

The complaint alleges that Los Angeles County\u2019s jail system was awash in smuggled drugs at the time. In 2023 alone, twelve inmates died of overdoses; in June 2024 six Twin Towers inmates went to the hospital for fentanyl exposure; in April 2024 a Sheriff\u2019s deputy was arrested for smuggling drugs into the jails; and in October 2024 jail staff administered Narcan to 187 people in a single mass overdose. Morgan\u2019s children and parents sued the county, the deputies, and the medical providers (Nurse Abass, Nurse Practitioner Orji, and Dr. Zubair), bringing six \u00a7 1983 claims (two deliberate indifference theories, three Monell theories, and interference with familial relations) and three state-law claims (negligence, the Bane Act, and California Government Code \u00a7 845.6 failure to summon medical care).<\/p>\n

The Court’s Holding<\/h2>\n

The court granted in part and denied in part the County\u2019s motion to dismiss, with surgical precision. Six claims survive in some form.<\/p>\n

The deliberate-indifference-to-dangerous-conditions claim against the Doe deputies survives. The court found a plausible inference that jailers knew about the proliferation of drugs in the County\u2019s jails \u2014 given the documented pattern of overdoses and even a deputy charged with smuggling \u2014 and failed to take available measures such as scanning incoming staff. The court rejected the County\u2019s sole counterargument as \u201cplainly belied by the record.\u201d<\/p>\n

The deliberate-indifference-to-medical-care claim, by contrast, was dismissed against Nurse Abass and Dr. Zubair without leave to amend. Abass had sent Morgan to the hospital for evaluation after the first overdose, re-evaluated him afterward, and arranged for follow-up. Zubair recommended a CT scan, which Morgan refused. The court found these allegations did not even amount to lack of due care, much less the \u201cformidable\u201d reckless-disregard standard. The claim against Orji (the nurse practitioner who saw Morgan for mental-health treatment) was dismissed with leave to amend because the complaint did not describe what Orji actually did during the visit.<\/p>\n

On Monell municipal liability, the court let only narrow theories survive: a failure-to-train claim regarding stopping drug smuggling into jails, and an unconstitutional-policy-of-inaction claim built on the same theory. Theories tied to medical care or vague policies (like an unexplained \u201cfailed booking policy\u201d or a \u201cone condition at a time\u201d medical policy) were dismissed because plaintiffs did not adequately allege the policies, deliberate indifference, or the predicate constitutional violations.<\/p>\n

The ratification claim was dismissed; plaintiffs did not plausibly allege that any policymaker had ratified specific unconstitutional conduct, and the Doe defendants by definition lacked \u201cfinal policymaking authority.\u201d<\/p>\n

The interference-with-familial-relations claim survives against the Doe deputies (because their alleged conscience-shocking deliberate indifference to drug proliferation can support the family-integrity theory) but not against the medical providers.<\/p>\n

On state law, the negligence claim against the County was dismissed without leave to amend because California Government Code \u00a7 815(a) bars common-law tort claims against public entities. The Bane Act claim failed against the medical defendants for the same reasons as the underlying deliberate-indifference claim. But the failure-to-summon-medical-care claim under \u00a7 845.6 survives against both the individual defendants and the County, because \u00a7 845.6 is the express statutory exception to the public-entity tort immunity that the County tried to invoke.<\/p>\n

Key Takeaways<\/h2>\n