AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The case involves the estate of Joseph Barela, a pretrial detainee who was found hanging in his cell at the Torrance County Detention Center (TCDC) on December 2, 2013. Prior to his death, Mr. Barela was placed in segregation for refusing a urinalysis screening. An autopsy revealed heroin concealed in his body and various drugs in his system at the time of death. The plaintiff, representing Mr. Barela's estate, alleged that the defendants were negligent in failing to provide proper medical and psychiatric care and in failing to prevent drugs from entering the TCDC, which contributed to Mr. Barela's death (paras 3-4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the defendants were negligent in failing to provide adequate medical and psychiatric care and in failing to prevent drugs from entering the TCDC. The plaintiff claimed that this negligence directly resulted in Mr. Barela's death. The plaintiff also contended that expert testimony was not required to establish the defendants' negligence in placing Mr. Barela in segregation and that the defendants' failure to follow their own policies constituted negligence per se (paras 4, 8).
• Defendants: Argued that the plaintiff could not establish the essential elements of duty and breach on her negligence claims due to the lack of expert witnesses to establish the required standard of care. The defendants also contended that the plaintiff did not have an expert witness to establish that Mr. Barela’s death was caused by the drugs found in his system (para 5).

Legal Issues

• Whether the district court erred in granting summary judgment in favor of the defendants.
• Whether expert testimony was required to establish the standard of care and causation in the plaintiff's negligence claims (paras 2, 7-8).

Disposition

• The Court of Appeals affirmed the district court's order granting summary judgment in favor of the defendants (para 14).

Reasons

• The Court of Appeals, consisting of Judge J. Miles Hanisee, Chief Judge M. Monica Zamora, and Judge Zachary A. Ives, held that the standard of care for screening and monitoring inmates for mental health issues and for preventing drug use by inmates is not within the knowledge of a lay juror and must be established by expert testimony. The court also found that the question of whether drugs contributed to Mr. Barela’s death required expert witness testimony. Since the district court had stricken the plaintiff’s experts as a sanction for failing to timely disclose them, the plaintiff could not establish her claims. The court rejected the plaintiff's argument that expert testimony was not required to establish negligence in placing Mr. Barela in segregation, noting that the plaintiff cited no authority suggesting that negligence per se applies to an entity’s failure to comply with internal rules or policies. The court concluded that the issues involved were beyond the knowledge of an average lay juror and affirmed the summary judgment in favor of the defendants (paras 7-13).