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Facts

  • Juventino Ceballos Hernandez, a Mexican national, experienced a distressing episode while staying with friends in Clovis, New Mexico. After exhibiting erratic behavior, local police were called to the scene. The responding officers' attempt to arrest Hernandez escalated to physical confrontation, resulting in Hernandez being restrained in a manner described as "hogtied" and subsequently dragged outside, which caused him physical injuries. Upon the arrival of an ambulance, Hernandez was transported to a hospital where he was kept restrained and administered medication, leading to a cardiac arrest that caused brain damage. Hernandez remained in a vegetative state for seven months before being returned to Mexico, where he later died (paras 4-11).

Procedural History

  • District Court of Curry County: Granted summary judgment in favor of Defendants on the wrongful death claim and dismissed the claim for negligent infliction of emotional distress. Directed verdict in favor of Defendants on the battery claim. Jury found for Defendants on the remaining claims (paras 12-13).

Parties' Submissions

  • Plaintiffs: Argued that Defendants' actions led to Hernandez's wrongful death, constituting excessive force and battery, and that the jury selection process was unconstitutional due to the exclusion of Hispanics (paras 14-15, 23-24).
  • Defendants: Contended that their actions did not constitute wrongful death as liability ended once Hernandez was delivered to the emergency room. Defended the jury selection process as non-discriminatory (paras 15, 22, 32-33).

Legal Issues

  • Whether the district court erred in granting summary judgment on Plaintiffs’ wrongful death claim by ruling joint and several liability does not apply.
  • Whether Defendants’ use of peremptory challenges resulted in the unconstitutional exclusion of Hispanics from the jury.
  • Whether the directed verdict on the battery claim was properly granted (paras 1-2, 14).

Disposition

  • The Court of Appeals reversed the summary judgment and jury verdict in favor of Defendants and remanded the case for a new trial (para 56).

Reasons

  • The Court of Appeals found that the district court erred in granting summary judgment on the wrongful death claim, as there were genuine issues of material fact regarding Defendants' liability and the foreseeability of Hernandez's injuries requiring medical attention. The court also agreed with Plaintiffs that the use of peremptory challenges by Defendants resulted in the unconstitutional exclusion of Hispanics from the jury, violating Batson v. Kentucky principles. The court did not address the directed verdict on the battery claim or other remaining issues as they may not reoccur at the re-trial or were not briefed (paras 15-21, 23-54).
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